Great Lakes Binational Toxics Strategy
Draft Report for
HEXACHLOROBENZENE (HCB):
SOURCES AND REGULATIONS
NOVEMBER 1,1999
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TABLE OF CONTENTS
1.0 INTRODUCTION
2.0 ENVIRONMENTAL AND HEALTH CONCERNS
3.0 SOURCES OF HCB
4.0 REGULATIONS AFFECTING HCB SOURCES
5.0 CURRENT PROGRAMS FOR HCB REDUCTION
6.0 CONCLUSIONS
7.0 REFERENCES
APPENDIX A
LIST OF TABLES
Table 1. Summary Information on Pesticide Active Ingredients Known to Contain HCB
as an Impurity
Table 2. 1997 HCB Releases (pounds) from Industrial Sectors Reporting to TRI
Table 3. Trends in Total HCB Releases (pounds) from 1990 to 1997 from TRI Data
Table 4. Facilities in EPA Region 5 Issued NPDES Permits between 1995 and 1999 to
Release HCB
Table 5. HCB Regulatory Overview
Table 6. Current Domestic and International Efforts Targeting HCB
Table 7. Summary of Current Status of Sources of HCB in the U.S.
LIST OF FIGURES
Figure 1. National 1990 HCB Emissions Estimated Using Section 112(k) Data
Figure 2. Trends in HCB Air and Water Releases Reported to TRI from 1990 to 1997 for All
Source Categories Combined
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1.0 INTRODUCTION
On April 7, 1997, Canada and the United States signed the Great Lakes Binational Toxics
Strategy: Canada-United States Strategy for the Virtual Elimination of Persistent Toxic
Substances in the Great Lakes (Binational Toxics Strategy or BNS). The Binational Toxics
Strategy identified twelve bioaccumulative substances having sufficient toxicity and presence in
water, sediments and/or aquatic biota of the Great Lakes system to warrant concerted action to
eliminate their input to the Great Lakes. They are called "Level 1 substances".
Hexachlorobenzene (HCB) is one of the Level 1 substances. HCB is the subject of this report,
which is in response to the "Challenge" written in the BNS:
Seek, by 2006, reductions in releases that are within, or have the potential to
enter the Great Lakes Basin, of HCB from sources resulting from human activity.
To guide Environment Canada (EC) and the United States Environmental Protection
Agency (EPA), along with their partners, as they work toward virtual elimination of the strategy
substances, the BNS outlined a four-step analytical framework:
1. Information gathering
2. Analyze current regulations, initiatives, and programs which manage or control
substances
3. Identify cost-effective options to achieve further reductions
4. Implement actions to work toward the goal of virtual elimination
This report documents the analysis associated with Steps 1 and 2 of the four-step process
for HCB. Step 1 encompasses identifying all sources, both within and outside the Great Lakes
Basin, by economic sector, that contribute to loadings in the Basin. Step 1 also requires
consideration of how the substance is used or released, its lifecycle, multi-media loadings, and
associated impacts. Step 2 involves assessing existing regulations and programs and how they
influence the presence of HCB in the Great Lakes Basin and long-range transport from other
areas into the Basin. Both Steps 1 and 2 involve identifying gaps: information gaps as to sources,
loadings, and impacts, and regulatory or programs gaps where there is opportunity to achieve
greater reductions in substance releases.
Section 2 of this report discusses HCB in the environment, its impact, and effects on
human health. Section 3 describes the sources of HCB and the available data sources in the Great
Lakes states that characterize releases of HCB. Regulations controlling sources of HCB are
outlined in Section 4, and non-regulatory programs aimed at reducing HCB releases are described
in Section 5. Conclusions are provided in Section 6.
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2.0 ENVIRONMENTAL AND HEALTH CONCERNS
2.1 DESCRIPTION OF HCB
Hexachlorobenzene (CAS registry number 118-74-1) belongs to a class of halogenated
aromatic hydrocarbons. HCB is a white, crystalline solid that is not highly water soluble. This
compound does not occur naturally. It was once used as a fungicide on the seeds of onion,
sorghum, wheat, and other grains under trade names such as AntiCarie, No Bunt, and Bunt-Cure.
Although there are no commercial uses of HCB in the U.S., it is formed as a byproduct in various
manufacturing processes, waste streams, and combustion operations. HCB is also found as a
trace byproduct or impurity in several currently used pesticides, chlorinated solvents, and other
chlorinated compounds (see Section 3.0).
2.2 ENVIRONMENTAL IMPACTS AND LOADINGS
HCB is a highly persistent environmental toxin due to its chemical stability and resistance
to biodegradation. In the atmosphere, HCB exists primarily in the vapor phase and degrades very
slowly. HCB is partially removed from the air by wet or dry deposition, but also remains in the
atmosphere and undergoes long range transport. In water, HCB partitions between the water
column, suspended matter and sediment. HCB is largely bound to the suspended matter and
sediment. HCB dissolved in water tends to migrate to the surface microlayer from which it
volatilizes fairly rapidly. Its strong absorption characteristics may cause lengthy persistence in
sediments. In soil, HCB binds strongly and generally does not leach into water. Transport to
ground water is slow, but varies with the organic makeup of the soil.
HCB bioaccumulates in fish, marine animals, birds, lichens, and animals that feed on fish
or lichens. In these species, HCB accumulates significantly in fatty tissues, including fat deposits
and the liver, with virtually no degradation by the exposed organisms. HCB can also accumulate
in wheat, grasses, vegetables and other plants. Environmental levels peaked in the 1970s and
have generally declined since that time, primarily due to the cancellation of HCB as a registered
pesticide.
A study of organochlorine levels in Lake Ontario lake trout showed an overall decline in
HCB concentrations from 1977 to 1993 of 92% to 22.4 ng/g (Huestis at al., 1996). This level is
still above the national average of 5.8 ng/g HCB detected at 46% of 400 sites across the U.S.
analyzed between 1986 and 1989 as part of EPA's National Study of Chemical Residues in Fish.
In that study, a maximum concentration of 913 ng/g was found in sea catfish of the Brazos River
in Freeport, Texas.
2.3 EXPOSURE AND HEALTH EFFECTS
HCB release to the environment is primarily the result of industrial and agricultural
activities. HCB may be emitted to air or released to waste water from facilities involved in the
production of chlorinated solvents and pesticides, from fossil fuel combustion sources (e.g., flue
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gases or fly ash), from waste incinerators, and from the use of pyrotechnic mixtures. Wastes
generated in production processes, such as aluminum plasma etching, represent another potential
source of release to the environment. Non-point source releases of HCB result from its presence
in several widely used pesticides. HCB releases from hazardous waste sites also contribute to
environmental loadings.
Humans may be exposed to HCB in the environment through inhalation, ingestion of
contaminated food, and skin contact with contaminated soil. HCB is toxic by all routes of
exposure. The EPA Carcinogen Assessment Group has placed HCB on a list of substances that it
considers possibly carcinogenic to humans. The International Agency for Research on Cancer
(IARC) also considers the substance to be possibly carcinogenic to humans (HSDB, 1999).
Short-term high exposures can lead to kidney and liver damage, central nervous system excitation
and seizures, circulatory collapse, and respiratory depression. Long-term low exposures may
damage a developing fetus, cause cancer, lead to kidney damage, liver damage, and fatigue, and
cause skin irritation.
2.4 SENSITIVE SUBPOPULATIONS AND GEOGRAPHIC REGIONS
The general population appears to be exposed to very low concentrations of HCB.
Primary exposure occurs through ingestion of contaminated food, particularly meat, dairy
products, poultry, and fish. Additional, although significantly less, exposure may occur through
inhalation or dermal contact.
Subpopulations who may be exposed to higher levels of HCB than the general population
include workers occupationally exposed to HCB, individuals living near facilities where HCB is
produced as a byproduct, and individuals living near current or former NPL hazardous waste sites
where HCB is present (ATSDR, 1999). Recreational and subsistence fishermen who consume
higher amounts of locally caught fish and bivalves (mussels, oysters, clams) from contaminated
waters and native populations who consume caribou and other game species are additional
Subpopulations with potentially higher exposure. Nursing infants may also be particularly
susceptible to high levels of HCB exposure.
HCB has been found in fish and wildlife throughout the U.S., but the Great Lakes has
been found to be an area of particularly high contamination (ATSDR, 1999). Data collected from
the National Oceanic and Atmospheric Administration's (NOAA) Mussel Watch Program show
that HCB concentrations in mussels from the Great Lakes, compared to HCB levels found in
mussels along marine coasts of the U.S. (East coast, West coast, Gulf coast, and marine waters),
were more than five times higher in the Great Lakes. The highest HCB concentrations were
found on the Niagara River at Buffalo, New York, and near Ashtabula, Ohio, in central Lake Erie
(Robertson and Lauenstein, 1998). The only fish advisories for HCB listed in EPA's 1995
National Listing of Fish Consumption Advisories were for Bayou D'Inde in Louisiana and the
Ashtabula River in Ohio.
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3.0 SOURCES OF HCB
HCB was synthesized and used from the 1940s to the late 1970s as a fungicide, primarily
on grain seeds such as wheat. HCB was voluntarily canceled for use as a pesticide in 1984 and is
no longer commercially manufactured as an end product in the U.S. However, HCB is formed as
a by-product, impurity, or intermediate in various manufacturing processes, including the
production of chlorinated solvents and pesticides. HCB is also formed as a product of incomplete
combustion in a variety of combustion and incineration processes. Control of HCB is hampered
by its long range atmospheric transport from other regions.
A complete picture of HCB releases and atmospheric processes is not clear. As mandated
by the 1990 Clean Air Act (CAA), Section 112(c)(6), EPA listed categories of sources accounting
for not less than 90 percent of aggregate emissions of HCB in the 1990 Emissions Inventory of
Section 112(c)(6) Pollutants (EPA, 1998a). However, due to the incompleteness of data used to
compile this inventory, the estimates for HCB air emissions for certain source categories are
currently in question. A revised inventory of 1990 HCB emissions was prepared by EPA for a
CAA Section 112(k) analysis and is expected to be included in the 1993 National Toxics
Inventory (NTI) due to be released in late 1999.
Major source categories of HCB are identified in the 1990 inventory data. Additional
sources of air emissions have been reported in literature studies. Some water and land releases
are reported in EPA's Toxics Release Inventory (TRI). Water releases may also be identified
through EPA's Permit Compliance System and waste releases through RCRA's Biennial
Reporting System. Environmental monitoring studies have shown soils and sediments of lakes
and rivers to be contaminated with HCB that may be recycled in the environment. HCB in land-
applied sewage sludge may also cycle through the environment. Finally, sources outside the Great
Lakes are thought to contribute to loadings within the Great Lakes due to long-range atmospheric
transport and deposition. Sources of HCB to air, water, and waste, as well as non-point and
reservoir sources, are described below.
3.1 AIR EMISSIONS
3.1.1 Sources for Which Inventory Estimates Exist
Inventory data prepared for the CAA Section 112(k) analysis and expected to be included
in the 1993 NTI were obtained from EPA (Pope, 1999). Figure 1 presents national 1990 HCB
emissions from these data. Total estimated HCB emissions for all source categories totaled
2.5 tons (5,000 Ibs) per year.
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Chemicals and
Allied Products r
Manufacturing /
2% /
Hydrochloric \ /
Acid Production^, \ /
Chlorinated 2o/ \ \ /
Solvents Production-^ ° n»^-^^_
ooq/ ^ /^^-^^"^^
^O /o /^^ ir&^^~^^^^
f^^^-S^
1 | p -n 1
Pesticide /^-^J^H h-J
Manufacture-^ 1
1 8% '
Tire Manufacturing
18%
MON - Continuous
Processes
5%
Pesticide Application
/^ 6%
,/ Chemical
^_ Manufacturing:
^ Alkalies and Chlorine
^A 9%
^jS\
\ Cyclic Crude
X^and Intermediate
Production
17%
Figure 1. National 1990 HCB Emissions Estimated Using Section 112(k) Data
Chlorinated Solvents Production
EPA estimates 1990 air emissions of HCB for chlorinated solvents production at 1,162
pounds per year, or approximately 23 percent of total national HCB emissions. This source
category includes the production of carbon tetrachloride, perchloroethylene, trichloroethylene,
ethylene dichloride, and 1,1,1-trichloroethane. HCB is generated as an impurity during the
manufacture of these chlorinated solvents, and a distillation process is used to separate HCB from
the finished products. Periodically, the distillation apparatus must be cleaned, which may generate
a higher than normal volume of waste.
No chlorinated solvent manufacturing facilities are located in the Great Lakes region.
Long-range transport of HCB generated outside the Great Lakes region may, however, contribute
to loadings within the basin.
Pesticides Manufacturing
HCB is generated as an impurity in the manufacture of chlorinated pesticides. EPA
regulates the maximum allowable concentrations of HCB as a contaminant in the following
pesticides: atrazine, chlorothalonil, dimethyltetrachloro-terephthalate (DCPA), lindane,
pentachloronitrobenzene (PCNB), pentachlorophenol, picloram, and simazine. The national
emissions estimate of HCB from pesticide manufacture is 916 pounds per year (Pope, 1999).
Although HCB may be generated as a trace impurity in atrazine, simazine, and lindane, these
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pesticides do not commonly contain HCB (Jensen, 1999). According to information obtained
from pesticide manufacturers, HCB concentrations range from 8 ppm in picloram to 22 ppm in
chlorothalonil and 3000 ppm in DCPA (Benazon, 1999).
Pesticides Application
When pesticides contaminated with HCB are applied to crops, lawns, or gardens, HCB is
released into the environment. Emissions from pesticide application result from volatilization of
the components of the pesticide formulation. The percent of HCB that volatilizes as air emissions
from contaminated pesticides has been estimated at 8%-80% (EPA, 1998; Nash and Gish, 1989;
Benazon, 1999). HCB emissions from pesticides application were estimated for the 1990 national
emissions inventory using a volatilization rate of 8.4%. With this volatilization rate, estimated
1990 HCB emissions are 292 pounds per year (Pope, 1999). Of this estimate, emissions of
dacthal, chlorothalonil, and PCNB account for 95%, due to a combination of HCB content and
annual usage. Table 1 provides information on the trade names, effect, and primary uses of
pesticide active ingredients that are known to contain HCB as an impurity.
Table 1. Summary Information on Pesticide Active Ingredients Known to Contain HCB
As An Impurity
Active Ingredient
Chlorothalonil
Dimethyl
Tetrachloro-
terephthalate
Pentachloronitro-
benzene
Picloram
Trade Names
Daconil 2787, Forturf, Bravo,
Exotherm Termil, Tuffcide
DCPA, Dacthal, Fatal, DAC
893, Dacthalor, Decimate
Terraclor, Tritisan, Quintozene,
PCNB, Terraclor Super X
Tordon, Borolin, Amdon, Pin,
Grazon
Effect
Fungicide
Herbicide
Soil fungicide,
seed dressing
agent
Systemic herbicide
Primary Use
Used on most crop plants
including greenhouse tomatoes
and ornamentals
Used on lawns, ornamentals,
onions, broccoli, cauliflower
Used to control damping off and
soil rot of cabbage, cauliflower,
peanuts, peppers, beans, garlic,
wheat, turf snow mold, and
various ornamentals
Used for a wide variety of deep-
rooted broadleaf weeds, in
brush control along utility rights-
of-way, and brush control in
pasture lands
In a study of agricultural pesticide use in the Great Lakes Basin (Brody et al., 1998),
chlorothalonil was found to be heavily used in the Lake Erie basin and to be among the top
pesticides used in the Lake Superior basin, though total pesticide use in the Lake Superior basin is
very low. Atrazine is also used in the Lake Superior basin and is widely applied in the Lake
Michigan and Lake Erie basins. The regions most affected by pesticide application appear to be
the western Lake Erie and southern Lake Michigan basins, primarily due to the amount of acreage
used for agricultural purposes, as compared to other Great Lakes basins.
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Tire Manufacturing
Estimated HCB emissions for tire manufacturing from the 1993 NTI data are 870 pounds
per year. However, the Rubber Manufacturers Association (RMA), a national trade association
for the rubber products industry representing all major U.S. tire manufacturers, is expected to
present a report indicating that HCB is not present at detectable levels in rubber processing
associated with tire manufacturing, based on tests conducted in July 1999.
In 1994 and 1995, the rubber manufacturing industry undertook a detailed study of
emissions from its various processes (mixing, milling, extruding, calendaring, and curing) in an
effort to help develop emission factors for the industry. The study involved testing 23 generic
rubber compounds representing a range of materials processed in the rubber industry. Specific
compounds used in the industry were not identified, as these are considered proprietary. HCB
was detected in the mixing process in 1 of 3 samples of Compound #3, this being a rubber latex
compound used as a tire belt coat. Concerns about the validity of this data point caused RMA to
retest this source of HCB in rubber processing (mixing and milling), under the original 1994
testing conditions, in July of 1999. The only deviation was to improve the detection limit of the
analysis by a factor of 10. EPA was directly involved in the testing, and the results will be shared
with EPA when they become available.
Cyclic Crude and Intermediate Production
Manufacturing facilities in the Standard Industrial Code (SIC) code 2865, cyclic crudes
and intermediates, that manufacture or process 25,000 pounds or otherwise use 10,000 pounds of
HCB are required to report transfers and releases to EPA's Toxics Release Inventory (TRI)
system. Reported TRI releases to air from this sector totaled 14 pounds in 1997 and came from
one chemical company in Memphis, Tennessee. Smaller companies may not meet the current
thresholds required for reporting to TRI. For more information regarding HCB releases reported
to TRI, see Section 3.5.
Chemical Manufacturing: Alkalies and Chlorine
Manufacturing facilities in the SIC code 2812, alkalies and chlorine, that manufacture or
process 25,000 pounds or otherwise use 10,000 pounds of HCB are required to report transfers
and releases to EPA's Toxics Release Inventory (TRI) system. Reported TRI releases to air from
this sector totaled 135 pounds in 1997 from major chemical companies. Smaller facilities may not
meet the current thresholds required for reporting to TRI. For more information regarding HCB
releases reported to TRI, see Section 3.5.
MOW - Continuous Processes
This source category receives its title from a regulation developed under EPA's MACT
program: Miscellaneous Organic NESHAP (MON). A National Emissions Standard for
Hazardous Air Pollutants (NESHAP) was promulgated for miscellaneous organic chemical
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production or processes, which will affect approximately 150 facilities in the following source
categories: benzyltrimethylammonium chloride production, carbonyl sulfide, chelating agents,
ethylidene norbomene, explosives production, hydrazine, photographic chemicals, rubber
chemicals, symmetrical tetrachloropyridine, paints and adhesives, and miscellaneous organic
chemical. These processes are distinguished from those in the Synthetic Organic Chemical
Manufacturing Industry (SOCMI), which are covered under a separate regulation.
Chemicals and Allied Products Manufacturing
Data for the 1993 NTI for this source category were extracted from TRI for SIC codes
2800 and 5161. A current search of TRI data for SIC codes 2800 and 5161 results in HCB
releases being reported only under SIC code 2812 (Chemical Manufacturing: Alkalies and
Chlorine), which is a subcode under 2800. It is assumed that manufacturing facilities formerly
included in SIC codes 2800 and 5161 are now categorized under SIC code 2812. Chemical
processes other than chlor-alkali are presumed to be covered under other SIC codes.
Hydrochloric Acid Production
This source category is comprised of about 44 companies operating 82 plants in the U.S.
Over 90% of the hydrochloric acid (HC1) produced in the U.S. is produced as a byproduct in the
manufacture of chlorinated organic chemicals such as vinyl chloride. The HC1 is typically used
captively in these processes. Most of the remaining HC1 is produced via direct synthesis from the
burning of hydrogen and chlorine gases. Many of these direct synthesis production units are co-
located at chlor-alkali plants, where excess chlorine gas is produced. Other manufacturing
processes include incineration of chlorinated organic waste gases, reaction of sulfuric acid with
metal chlorides, and fumed silica production. HC1 gas is typically recovered as a product
(hydrochloric acid) via absorption in water. Exhaust gas from HC1 absorbers is typically routed
through a caustic scrubber. However, it was found that some waste gas incineration facilities do
not recover and/or control HC1. Emissions of HC1 and/or chlorine gas are also expected from
storage tanks, process equipment leaks, and process vents associated with HC1 production.
3.1.2 Other Potential Sources
Although not included in the CAA Section 112(k) inventory, other potential sources of
HCB emissions have been discussed in U.S. and Canadian literature and reports. These are
described below.
Utility Coal Combustion
Utility coal combustion was not identified as a source category of HCB in the 1990 data
used for the 1993 NTI but was reported to account for 30 percent of total national HCB
emissions in EPA's 1990 Emissions Inventory of Section 112(c)(6) Pollutants (EPA, 1998a). The
method employed to obtain the emissions estimate for this report has led to considerable
uncertainty regarding the potential for coal-burning utilities to emit HCB. EPA has indicated that
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the single highest measurement was used in calculating an emissions estimate for utility coal
combustion for the Section 112(c)(6) inventory.
The Electric Power Research Institute (EPRI) believes that utility coal combustion is not a
significant source of HCB. EPRI sponsored the industry study of 14 coal-fired utility plants in the
U.S. and averaged the results of three tests performed at each facility (using one-half the detection
limit when HCB was not detected) to conclude that HCB was not detected at any of the sites
tested. Although HCB may have been detected in some of the runs, the average of three test runs
at each facility was below the detection limit.
Additional evidence that utility coal combustion is not a significant source of HCB comes
from the results of stack tests performed at three Ontario coal-fired utilities. HCB was not
measured above the detection limit (0.02 ng/m3) at any of the facilities tested. Until the
uncertainties with EPA's inventory estimate can be resolved, HCB emissions from utility coal
combustion cannot be confirmed.
Aluminum Degassing
The use of hexachloroethane (HCE) fluxing agents to degas molten aluminum in
secondary aluminum operations has been reported to release HCB (Westberg et al., 1997).
However, the Aluminum Association has indicated that no large secondary aluminum operations
use HCE as a fluxing agent in the U.S., and none of the small secondary aluminum furnaces that
reported using HCE fluxing agents are located in the Great Lakes region.
Waste Incineration and Cement Kilns
HCB emissions as a result of the incomplete decomposition of chlorinated substances have
been reported for municipal waste, medical waste, hazardous waste, and sewage sludge
incinerators, as well as for cement and aggregate kilns (Benazon, 1999; Cohen et al. 1995).
Emissions of HCB from municipal waste combustion units, medical waste incinerators, and
cement and lightweight aggregate kilns burning hazardous waste may be controlled by recent
regulations requiring standards to reduce air toxics for these source categories (see Section 4.0).
Open Barrel Trash Burning
HCB was detected in an emissions characterization study undertaken by EPA to quantify
emissions from the simulated burning of household waste material in barrels (EPA, 1997). An
emission factor was developed for HCB in units of pounds emitted per ton of waste burned, but
no estimate of emissions from open trash burning was made. Difficulties in estimating emissions
include understanding how the characteristics of the waste and burning method affect HCB
emissions, as well as estimating activity levels for open trash burning. Open trash burning is
thought to be a common practice in many rural townships and tribal communities of the Great
Lakes. It is estimated that 95 percent of some 578 tribes in the U.S. practice open burning as a
means of reducing volumes of garbage (Cummings, 1999).
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Wood Preservation
HCB has been identified as a pesticide contaminant is the wood preservative
pentachlorophenol (also known as "penta" or "PCP"), which is used to protect utility poles,
railroad ties, and roadway guardrail posts. EPA permits HCB concentrations in
pentachlorophenol no greater than 75 ppm. However, a pentachlorophenol manufacturer claims
the average concentration of HCB in pentachlorophenol is 40 ppm (mg/kg). Based on
information provided by the Penta Council, a trade organization of American wood preservers, a
typical treated 40-ft utility pole contains about 10 pounds of PCP. From this information, the
concentration of HCB in a newly treated 40-ft utility pole can be calculated as about 181 mg of
HCB per pole. A study commissioned by the Penta Council shows that HCB is released to the
atmosphere through volatilization and, depending on the depth of penetration of the PCP,
volatilization rates range from 12% to 36%. HCB in PCP-treated utility poles also has the
potential to leach and contaminate the surrounding soil (WLSSD, 1998).
There are no estimates of the approximate number of PCP-treated utility poles, railroad
ties, and roadway guardrail posts in use in the Great Lakes basin. Old railroad ties and utility
poles may be used in alternative ways, such as to build decks and gardens and playground
equipment, that may result in higher human exposure than in their original use, due to their closer
proximity to human activities.
Sewage Treatment Plants
HCB in sewage sludge may volatilize during process operations or be released to surface
water in the effluent. HCB may also volatilize from sewage sludge applied to land. As discussed
above, HCB emissions may also result from incineration of sewage sludge. The quantity of HCB
present at sewage treatment plants varies by treatment plant, depending on the type of wastewater
discharge received (e.g., rural, urban, industrial) and the type of treatment conducted.
The source of HCB at sewage treatment plants may be the receiving influent, either from
individual facilities discharging HCB wastes or the resuspension of contaminated sediments, or
the use of HCB-contaminated ferric chloride in treatment operations (Benazon, 1999; WLSSD,
1998). Ferric chloride is a chemical used in wastewater treatment and water purification to
control odor and to facilitate settling of particles in the water. Although the source of HCB
contamination of ferric chloride has not been determined, it may be due to its manufacture from
low-grade hydrochloric acid (HC1) leftover from other industry operations (WLSSD, 1998).
Other Emissions
The draft Inventory of HCB Emissions/Releases for Ontario reports HCB releases from
iron and steel production, and from wood and biomass burning. Additional HCB sources
identified by Canada in support of the development of a North American Regional Action Plan for
the Sound Management of Chemicals Program include coal production, paint manufacturing,
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pyrotechnics and ordinance production, soap production, pulp and paper mills, and textile mills
(SMOC, 1998).
3.2 WATER RELEASES
TRI reports indicate that pesticide and chlorinated solvent manufacturers periodically
discharge HCB to local water bodies. In 1997, 250 pounds of HCB were reported released to
water by the alkalies and chlorine sector and 26 pounds by the agricultural chemicals sector (see
Section 3.5).
Wastewater treatment plants may be the recipients of HCB waste water discharged from
industrial facilities. As part of the Zero Discharge Pilot Project, Western Lake Superior Sanitary
District (WLSSD) in Duluth, Minnesota, is examining the contribution of HCB, and other toxic
substances, to its facilities from internal and external sources.
3.3 LAND RELEASES AND HAZARDOUS WASTES
HCB is listed as a hazardous waste and is regulated under the Resource Conservation and
Recovery Act (RCRA). Chlorination processes produce HCB-containing tars and wastes in
chlor-alkali, chlorinated solvents, semiconductor, and pesticide manufacturing sectors. Past
methods of disposal of these wastes have included landfill disposal, discharge to municipal sewage
treatment plants, and incineration. If not properly managed, landfills are a potential source of
HCB release to the environment. This has been most apparent in the HCB releases to the St.
Clair River from the Dow Chemical Scott Road landfill in Sarnia, Ontario. In recent years, Dow
has taken measures to remediate this landfill and minimize the release of contaminants. It is not
known the degree to which other landfills, previously used to dispose of HCB wastes from the
chlor-alkali, chlorinated solvent, or pesticide industries, may be in similar need of remediation.
EPA is currently investigating the presence of several Level 1 chemicals in landfill leachate
(Cummings, 1999). High-temperature incineration (around 1300 C) with a retention time of
0.25 seconds is the recommended method of disposal for HCB because of the greater than 99%
destruction efficiency (ATSDR, 1999). However, varying conditions of high-temperature
incineration can also produce other toxic chlorinated compounds.
3.4 NON-POINT AND RESERVOIR SOURCES
Long Range Transport
Long range atmospheric transport and deposition of HCB contributes to local HCB
contamination. The relative contribution of long-range sources varies depending on several
factors. For example, Cohen et al. (1995) found that the relative contribution of different sources
to the deposition of HCB in the Great Lakes was dependent upon proximity of the sources to the
Great Lakes, weather patterns (i.e., the prevailing wind direction), and the level of activity of the
emission source. In this study, the relative effects of pesticide applications in diverse areas were
assessed. The largest source of HCB emissions from pesticide application was the Province of
Ontario, followed by Texas, Michigan, Georgia, Illinois, and California. The contribution from
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Ontario was due to its proximity to the Great Lakes as well as the abundant use of HCB-
contaminated pesticides in this province. Contributions from states relatively distant from the
Great Lakes reflected in part their high-level use of HCB-contaminated pesticides.
There is evidence that HCB is distributed globally, as supported by concentrations of HCB
found in the Arctic, away from any sources of HCB, and by similar concentrations of HCB in air
over regions as far apart as Norway, the Great Lakes, and Bermuda (Cohen et al., 1995). More
research on long-range transport modeling of HCB is needed to gain a better understanding of the
contribution from long-range transport and deposition
Soil/Sediment
EPA's 1998 report '"Hie Incidence and Severity of Sediment Contamination in Surface
Waters of the United States" indicates that atmospheric deposition, industrial discharges,
municipal discharges, and urban sources are ongoing sources contributing to organic chemical
sediment contamination. In the Great Lakes, HCB was identified as a contaminant contributing to
the classification in the report of the following sites as Tier 1 or Tier 21: Ashtabula-Chagrin,
Buffalo-Eighteenmile, Chautauqua-Conneat, St.Clair-Detroit, Lake St.Clair, Lower Fox,
Manistee, Cedar-Portage, Niagara, Oak Orchard-Twelvemile, Ottawa-Stony, Tuscarawas, and
Upper Ohio. A maximum concentration of HCB in sediment samples of 32 ppm was measured in
the Ashtabula-Chagrin watershed (southern Lake Erie).
Data collected at historically contaminated sites in the Great Lakes region over the last 10
to 20 years have shown decreasing concentrations of HCB. A decrease of approximately 57
percent was seen in HCB levels in suspended solids from the mouth of the Niagara River over the
period 1989-1996 (Niagara River Interpretation Group, 1992-1998, as presented in Benazon,
1999). The decreasing trends in the Great Lakes are likely the result of the elimination of major
sources of release in the region; however, as discussed above, non-point urban sources are
ongoing sources.
Eleven sites in EPA Region 5 are currently on the EPA Superfund Program's final
National Priority List (NPL) with HCB listed as a contaminant of concern for all media
(http://www.epa.gov/superfund/sites/index.htm). NPL sites are the most serious hazardous waste
sites in the U.S. as identified by EPA's Superfund Program for long-term federal cleanup
activities. The sites containing HCB in EPA Region 5 are listed in Appendix A.
3.5 DATA SOURCES FOR THE GREAT LAKES STATES
HCB releases are reported under several different federal and state programs. Each
program deals with a different set of regulatory requirements and a different subset of the
1 Tier 1 sites are those where associated adverse effects are probable. Tier 2 sites are those
where associated adverse effects are possible, but expected infrequently.
12
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regulated community. HCB release information is available from three federal reporting
programs:
the Toxic Chemical Release Inventory (TRI),
RCRA Biennial Report System (BRS) data, and
the Permit Compliance System (PCS) data for water releases.
In addition to these federal reporting programs, ambient air and precipitation monitoring is
conducted at several sites in the Great Lakes Basin through the Integrated Atmospheric
Deposition Network (IADN) and Environment Canada ambient air monitoring.
Information from each of these sources is summarized below and included in detail in
Appendix A. Where information was available, data are shown by SIC code to illustrate the
distribution of HCB releases across industrial sectors. Appendix A provides a summary of the
number of facilities that report HCB releases under each of these programs. The number of
facilities reporting releases varies by reporting program as a result of differing reporting
requirements.
Toxic Chemical Release Inventory (TRI)
The Toxic Chemical Release Inventory (TRI) contains chemical release and transfer
information from manufacturing facilities (SIC codes 20-39) which have ten or more employees
and that manufacture or process 25,000 pounds of a listed chemical or otherwise use 10,000
pounds of a listed chemical. Electric utilities do not fall into the SIC code range covered by TRI
and therefore do not report any HCB releases under this program. Table 2 shows 1997 TRI data
by industrial sector for U.S. facilities reporting HCB releases. In 1997, 9 facilities reported HCB
releases, up from 8 facilities that reported in 1996. The majority of HCB releases reported in
1996 and 1997 came from GB Biosciences Corporation of Houston, Texas, whose primary
industrial activity is agricultural chemicals. No facilities reporting HCB releases were located in
the Great Lakes Basin.
By far, the majority of releases in 1996 and 1997 were transfers off-site to locations other
than publicly owned treatment works (POTWs) for disposal. The methods used to dispose of
HCB-containing waste by facilities receiving these transfers are reported to include
landfill/disposal surface impoundment and incineration/thermal treatment.
13
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Table 2. 1997 HCB Releases (pounds) from Industrial Sectors Reporting to TRI
Industrial Sector
Alkalies & Chlorine
Agricultural Chemicals, nee
Cyclic Crudes &
Intermediates
SIC
Code
2812
2879
2865
Air-
Fugitive
106
5
14
Air-
Stack
29
Underground
Injection
139
Off-Site
Transfers
6
12,032
Releases to
Water
250
26
Other than to publicly owned treatment works (POTWs).
Table 3 shows the trends in total HCB releases from 1990 to 1997 by industrial sector.
Table Al in Appendix A shows the trends in HCB releases reported to TRI from 1990 to 1997 by
industrial sector and release category.
Table 3. Trends in Total HCB Releases (pounds) from 1990 to 1997 from TRI Data
Industrial Sector
Alkalies & Chlorine
Agricultural
Chemicals, nee
Cyclic Crudes &
Intermediates
Discontinued,
Changed, or
Unknown
Industrial Organic
Chemicals, nee
Cement, Hydraulic
SIC
Code
2812
2879
2865
2800
2869
3241
1997
530
12,063
14
0
0
1996
1,176
23,470
14
0
1995
7,129
7,335
15
0
1994
628
940,744
12
0
23
1993
1,324
648,006
0
340
1992
5,169
28,619
4
80
0
1991
518
1,065,057
22
209
0
1990
768
34,091
830
115
Figure 2 shows the trends in HCB air and water releases reported to TRI from 1990 to
1997 for all source categories combined.
14
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5000
Year
Figure 2. Trends in HCB Air and Water Releases Reported to TRI from 1990 to
1997 for All Source Categories Combined
1996 National Toxics Inventory
[Data not yet available]
RCRA Biennial Report Data
The RCRA Biennial Report System (BRS) tracks information on hazardous waste
generated and managed by large quantity generators and permitted Treatment, Storage, and
Disposal (TSD) facilities. RCRA wastes containing HCB are identified by waste code "D032",
which indicates that HCB is a characteristic hazardous waste in a waste stream or discarded
product. HCB wastes may be also identified by other wastes codes associated with hazardous
waste from specific sources. For example, waste code KOI6 describes heavy ends or distillation
residues from the production of carbon tetrachloride. Appendix A shows the number of facilities
in Great Lakes states reporting HCB-bearing waste streams to BRS. A total of 69 facilities in
Great Lakes states reported HCB-bearing waste streams.
Reporting SIC code and source code are optional in BRS and are not available for all
facilities. Therefore, a summary of BRS data by industrial sector and source process could not
reliably be generated for facilities reporting HCB-bearing waste streams.
15
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Permit Compliance System (PCS) Data
EPA's Permit Compliance System (PCS) data for water discharges approximates point
source loads from municipal and industrial dischargers. The information is based on
monitoring data supplied by regulated facilities. EPA uses PCS data as the basis for its National
Pollutant Discharge Elimination System (NPDES) permit enforcement program. Table 4 presents
PCS data by industrial sector for regulated facilities in EPA Region 5 issued permits between
January 1, 1995 and August 31, 1999. These are facilities that were issued permits to discharge
HCB. Table 4 does not imply release of HCB; data on actual discharges of HCB could not be
obtained. Appendix A lists the number of facilities in Great Lakes states holding NPDES permits
to discharge HCB from EPA's Permit Compliance System.
Table 4. Facilities in EPA Region 5 Issued NPDES Permits between 1995 and 1999 to
Release HCB
Industrial Sector
Sewerage Systems
Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
Paper Mills
Electric Services
Industrial Organic Chemicals, nee
Cyclic Crudes and Intermediates
Other
SIC Code
4952
2821
2621
4911
2869
2865
-
Number of Permits Issued
25
10
6
3
3
2
11
Integrated Atmospheric Deposition Network
The Integrated Atmospheric Deposition Network (IADN) was established by the U.S. and
Canada for conducting air and precipitation monitoring in the Great Lakes Basin. IADN was
created as part of the 1987 amendments to the Great Lakes Water Quality Agreement through the
adoption of Annex 15. Currently, the network consists of five Master Stations and 14 Satellite
Stations in both Canada and the U.S. which measure wet deposition and air concentrations of gas
and particulate organics and trace elements. Data comparing the wet and dry deposition, gas
absorption, and gas volatilization for HCB for 1994 show that HCB appears to be volatilizing out
of the lakes (IADN, 1998). Appendix A includes precipitation, particle, and gas concentration
data from IADN Master Stations for HCB from 1992-1994.
Environment Canada
The Analysis and Air Quality Division of Environment Canada conducts ambient air
monitoring of over 300 contaminants, including HCB, at locations around the country. In a 1997
unpublished report entitled "Monitoring of Persistent Toxic Substances in Ontario-Great Lakes
16
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Basin", the median concentrations of HCB in ambient air collected at Windsor and Walpole Island
showed that essentially the same levels were measured in 1987-1990 as in 1996-1997. The report
also concluded that very small variability was measured between all Ontario sites and that HCB
appears to have minimal local influences in Ontario but a uniform regional concentration of about
0.1 ng/m3(Dann, 1997).
4.0 REGULATIONS AFFECTING HCB SOURCES
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), regulates registration
and use of commercially produced substances created for the purpose of pest control. FIFRA
requires all pesticides sold or distributed in the U.S. (including imported pesticides) to be
registered by EPA. Under FIFRA (40 CFR Subchapter E), HCB was voluntarily canceled for use
as a pesticide in 1984. Cancellation of a pesticide imposes a date when sale and distribution may
no longer take place (usually 18 months from the effective date of cancellation), but allows for the
use of existing stocks.
Because HCB has been canceled for use as a pesticide and is not a naturally occurring
compound, the major regulations currently controlling its release are those governing its
generation as a byproduct in the pesticide and chlorinated solvent industries. In addition, releases
of HCB are required to be reported by certain manufacturing facilities to EPA's Toxics Release
Inventory System. Table 5 provides an overview of HCB regulations under the Clean Air Act
(CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SOWA), the Resource
Conservation and Recovery Act (RCRA), and the Comprehensive Environmental Response,
Compensation, and Liability Act (CERLA).
Clean Air Act
In the U.S., the Clean Air Act (CAA) establishes requirements for airborne emissions from
a variety of sources. USEPA, state, and regional air quality agencies are all likely to be involved
in CAA implementation. Under the CAA, the major regulatory requirements include National
Emissions Standards for Hazardous Air Pollutants (NESHAPS)/Maximum Achievable Control
Technology (or MACT standards) for a specific list of hazardous air pollutant source categories
and subcategories. Hexachlorobenzene is included on this list. The CAA also establishes the
national ambient air quality standards, which although they have no direct regulatory impact,
serve as baseline for judging the effectiveness of release regulations. Currently, there is no
ambient air standard established under the CAA for HCB.
EPA's Air Toxics Rule for Pesticide Active Ingredient (PAI) Production promulgates
national emission standards for hazardous air pollutants (HAP) as required under Section 112 of
the Clean Air Act. This rule will require newly built and existing PAI manufacturing operations to
reduce HAP emissions to the level corresponding to the maximum achievable control technology
by using either an add-on control device or a pollution prevention (P2) alternative to control
emissions from process vents. The standards regulate a variety of PAI processes, including the
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production of chlorothalonil and dacthal. The rule requires monitoring of HAP emissions to
demonstrate compliance or submission of a Pollution Prevention Demonstration Summary, if
alternate P2 options are used to meet the standards. Expected reductions in HCB emissions are
not known, but HAP emissions from existing facilities are expected to be reduced by 65 percent
from the baseline emission level (http://www.epa.gov/ttn/uatw/pest/fr62399s.html).
Standards of performance for equipment leaks of Volatile Organic Compounds (VOC) in
the Synthetic Organic Chemical Manufacturing Industry (SOCMI) have been promulgated under
40 CFR 60.489 (7/1/97). The intended effect of these standards is to require all newly
constructed, modified, and reconstructed SOCMI process units to use the best demonstrated
system of continuous emission reduction for equipment leaks of VOC, considering costs, non-air-
quality health and environmental impact and energy requirements. Hexachlorobenzene is
produced, as an intermediate or a final product, by process units covered under this subpart.
Emission standards required under the Synthetic Organic Chemical Manufacturing Industry
Hazardous Organic NESHAP (SOCMI HON) (40CFR 63.100) will control emissions of organic
HAP emissions from chemical manufacturing processes in the synthetic organic chemical
manufacturing industry.
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Table 5. HCB Regulatory Overview
CAA
§112(b):
Designated a
HAP; Major
source
categories
identified under
§112(c)(6);
NESHAPS
established for
SOCMI (40CFR
63.100); other
MACT
standards to be
promulgated.
Air toxic rule for
pesticide active
ingredient
production
(62FR 60566)
CWA
CWA Priority:
Listed priority
pollutant
(40CFR 423);
subject to
NPDES effluent
limitations
under §304(b)
(40CFR 122)
and general
pretreatment
(40CFR 403)
Bioaccumulativ
e Chemical of
Concern (BCC)
under the Great
Lakes Water
Quality
Guidance
SDWA
NPDWR /MCL:
0.001 mg/L
(enforceable)
MCL goal is
zero
RCRA
Subtitle C:
HCB-containing
substances are
characterized
as(D032)
hazardous
wastes - many
asF&K
wastes (40CFR
261. 24 and
261.32); subject
to hazardous
waste
regulations
(40CFR 261.1)
HCB is also
listed as a Toxic
Commercial
Pesticide
Product (U127)
(40 CFR
261.33)
Universal
treatment
standards for
HCB in waste
(40CFR 268.48;
some F, K, and
U wastes with
HCB as a
regulated
treatment
performance
constituent prior
to disposal can
be found in
CFR 268.40)
SARA/EPCRA
§313: Releases
(by facilities with
10 or more
employees and
that process
25,000 Ibs., or
otherwise use
10,000 Ibs.)
must be
reported to TRI
(40CFR 372.65)
Jan. 5, 1999
Federal Register
proposed
reduction of TRI
reporting
threshold to 10
Ibs. per year
(64FR 687)
CERCLA
§103: Spills of
HCB>10lbs.
must be
reported to the
National
Response
Center
CAA: Clean Air Act NPDES: National Pollutant Discharge Elimination
CERCLA: Comprehensive Environmental Response, System
Compensation, and Liability Act NPDWR: National Primary Drinking Water
CWA: Clean Water Act Regulations
HAP: Hazardous Air Pollutant RCRA: Resource Conservation and Recovery Act
MCL: Maximum Contaminant Level (drinking water SARA/EPCRA: Superfund Amendment
standard) Reauthorization Act / Emergency Planning and
NESHAPS: National Emissions Standards for Community Right-to-know Act
Hazardous Air Pollutants (HAPs) SDWA: Safe Drinking Water Act
SOCMI: Synthetic Organic Chemical Manufacturing
Industry
TRI: Toxics Release Inventory
19
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Emissions limits based on "maximum achievable control technology" (MACT) have been
established for municipal waste combustion units and medical waste incinerators to address,
among other pollutants, organic emissions. Similarly, regulations have been promulgated to
control hazardous air pollutant emissions from incinerators, cement kilns, and lightweight
aggregate kilns that burn hazardous waste. These standards will have a beneficial effect on HCB
emissions from municipal and medical waste incinerators and incinerators, cement kilns, and
lightweight aggregate kilns burning hazardous waste.
Clean Water Act
The Clean Water Act (CWA) regulates discharges to surface waters with the overall goal
to restore and maintain the chemical, physical, and biological integrity of the nation's surface
waters. To control point source discharges, the CWA established the National Pollution
Discharge Elimination System (NPDES) permit program, which defines the conditions and
effluent limitations under which a facility may make a discharge. The NPDES permit is the
regulatory tool translating the general standards (CWA, Subchapter III) into effluent limitations
and monitoring requirements applicable to specific point source polluters. Indirect discharges via
municipal wastewater treatment plants or sewage treatment plants must meet pre-treatment
requirements, including categorical standards developed by the EPA that apply to each industry
and local standards developed by each publicly owned treatment work (POTW). Effluent
guidelines regulations for both direct discharges and pre-treatment standards are generally sector
specific, for example for a particular segment of industry. To address the risk of contaminated
runoff, NPDES storm water permits are also required for any storm water discharge associated
with industrial activity, a large or medium municipal storm sewer system, or a discharge which
EPA or the State determines to contribute to a violation of a water quality standard or is a
significant contributor of pollutants to waters of the United States.
Safe Drinking Water Act
The Safe Drinking Water Act (SOWA) was established by Congress in 1974 to protect
human health from contaminants in drinking water, and to prevent contamination of existing
groundwater supplies. The SDWA National Primary Drinking Water Standards define
enforceable maximum contaminant levels (MCLs), in addition to non-enforceable maximum
contaminant level goals (MCLGs). The maximum contaminant level for HCB is 0.001 mg/L
(1 ppb), and the maximum contaminant level goal is zero.
RCRA Requirements
The Resource Conservation and Recovery Act (RCRA) establishes a regulatory structure
for the handling, storage, treatment, and disposal of solid and hazardous wastes. Subtitle C of
RCRA addresses "cradle-to-grave" requirements for hazardous waste from the point of
generation to disposal. A solid waste containing hexachlorobenzene may become characterized as
a hazardous waste when subjected to testing for toxicity as stipulated in 40 CFR 261.24, and if so
characterized, must be managed as a hazardous waste. As stipulated in 40 CFR 261.33, when
20
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HCB, as a commercial chemical product or manufacturing chemical intermediate or an
off-specification commercial chemical product or a manufacturing chemical intermediate, becomes
a waste, it must be managed according to Federal and/or State hazardous waste regulations. Also
defined as a hazardous waste is any residue, contaminated soil, water, or other debris resulting
from the cleanup of a spill, into water or on dry land, of this waste. Generators of small quantities
of this waste may qualify for partial exclusion from hazardous waste regulations (40 CFR 261.5).
CERCLA Reportable Quantities
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), or Superfund, establishes a list of hazardous substances which are subject to release
reporting regulations. Releases of CERCLA listed hazardous substances, if occurring in amounts
exceeding a predefined "reportable quantity" (RQ), must immediately be reported to the National
Response Center. Persons in charge of vessels or facilities are required to notify the National
Response Center (NRC) immediately, when there is a release of this designated hazardous
substance, in an amount equal to or greater than its reportable quantity of 10 Ib (4.54 kg).
Superfund Amendment and Reauthorization Act
(Emergency Planning and Community Right-to-Know Act)
The Superfund Amendment and Reauthorization Act, known as SARA Title III, or the
Emergency Planning and Community Right to Know Act (EPCRA), also requires notification and
reporting of hazardous substances. The key regulatory requirements of EPCRA include
emergency planning and release notification, Community Right-to-Know reporting, and Toxic
Release Inventory (TRI) reporting. Toxic release reporting requirements, which allow for the
compilation of the national Toxic Release Inventory (TRI) database, apply to specific
manufacturing facilities, which have ten or more employees, and which manufacture, process, or
use specified chemicals in amounts greater than threshold quantities. Emergency planning is
required when substances on the Extremely Hazardous Substances list are present in quantities
exceeding the Threshold Planning Quantities (TPQs).
Principal provisions of SARA Title III that affect HCB reporting are the following. All
facilities in the manufacturing sector (SIC codes 20 - 39) that manufacture or process 25,000
pounds of a listed chemical or otherwise use 10,000 pounds of a listed chemical must report air,
water, and land releases to TRI. TRI thresholds are based on the quantity of each substance used,
processed, manufactured, or imported at any of these facilities. Beginning with the 2000
reporting year, the threshold for reporting HCB releases to TRI is expected to be lowered to 10
pounds per year. The purpose of the proposed lowering of the reporting threshold is to capture a
vast majority of sources that release HCB that are not required to report under the current
reporting threshold. The proposed rule was announced January 5, 1999 (64FR687), and a final
rule is expected by the end of 1999. Reporting would begin in 2000, and the first public release of
data obtained through the new TRI rule would be available in 2001.
OSHA
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No Occupational Safety and Health Standards exist for HCB.
Transport Methods and Regulations
No person may transport, offer, or accept a hazardous material for transportation in
commerce unless that person is registered in conformance and the hazardous material is properly
classed, described, packaged, marked, labeled, and in condition for shipment as required or
authorized by the hazardous materials regulations (49 CFR 171.2 (7/1/96)).
State Laws
In addition to federal clean water requirements, every state also regulates water pollution
within their territory. This sometimes results in a dual system of permitting, whereby each facility
must obtain both a federal NPDES permit and a state discharge permit. States can gain EPA
approval of the state permitting system so that the state itself administers the NPDES program.
In such cases, one permit issued by the state government meets both the federal and state
requirements. States have the explicit right to enact any water quality standard or limitation that
is more stringent than those required by federal statute (33 U.S.C. sec. 1370). Indiana, Michigan,
Minnesota, New York, Ohio, and Wisconsin have set water quality standards or guidelines for
HCB (ATSDR, 1999).
The states of Indiana, Michigan, New York, and Pennsylvania have set average acceptable
ambient air concentrations for HCB. Illinois, Minnesota, and Pennsylvania have defined a
hazardous waste toxicity characteristic for HCB. Open trash burning may be regulated by state
(e.g., Michigan, Minnesota) and local laws.
5.0 CURRENT PROGRAMS FOR HCB REDUCTION
Since the toxics effects of HCB have become known, releases of HCB to the
environment have been curtailed dramatically, primarily through reductions in its use as a
pesticide and a pesticide by-product. More recently, HCB has become a concern regionally in
the Great Lakes with the signing of the Great Lakes Water Quality Agreement and the
Binational Toxics Strategy, nationally through EPA's Draft Agency-wide Multimedia Strategy for
Priority Persistent, Bioaccumulative, and Toxic (PBT) Pollutants (PBT Strategy)
(http://www.epa.gov/pbt/pbtstrat.htm), and internationally in global POPs negotiations. At the
same time, studies are being undertaken to assess HCB loadings in the environment and to
characterize human exposure. Table 6 describes these and other current domestic and
international data collection and toxic reduction efforts targeting HCB.
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Table 6. Current Domestic and International Efforts Targeting HCB
Current Domestic and International Efforts Targeting HCB
Program
Description
National and Regional Strategies
Binational Toxics
Strategy (BNS)
The BNS challenges the U.S. to seek reductions in HCB releases from
sources resulting from human activity by 2006. The BNS provides an
established process for engaging stakeholders and seeking voluntary
reduction efforts through an HCB Workgroup. The workgroup offers an
opportunity for EPA to solicit and recognize efforts toward the virtual
elimination of HCB in the Great Lakes. An additional challenge of the BNS
is to assess atmospheric inputs of strategy substances to the Great Lakes
and, if long-range sources are confirmed, to work within international
frameworks to reduce releases of such substances.
EPA's Agency-wide
Multimedia Strategy for
Priority Persistent,
Bioaccumulative, and
Toxic (PBT) Pollutants
Building on the BNS, the PBT Strategy seeks to reduce risks from
persistent toxic substances at a national level. The PBT Strategy targets
HCB as a Level 1 pollutant. The aim of the PBT Strategy is to respond to
the cross-media issues associated with PBT pollutants by going beyond
the traditional single-statute approaches in order to reduce risks to human
health and the environment from existing and future exposure to PBT
pollutants. The PBT national action plan for HCB will seek to coordinate
efforts among all EPA national and regional programs as well as to
collaborate with international organizations to reduce risks from current
and future exposure to HCB.
EPA's Integrated Urban
Air Toxics Strategy
This strategy identifies 33 air toxics, including HCB, that present the
greatest threat to public health in the largest number of urban areas.
Building on its existing air toxics regulatory program, key components of
the strategy are 1) regulations addressing sources at both the national and
local level, 2) initiatives to identify and address specific community risks
(e.g., though pilot projects), 3) air toxics assessments (including expanded
air toxics monitoring and modeling) to identify areas of concern, to
prioritize efforts to reduce risks, and to track progress, and 4) education
and outreach efforts to inform stakeholders about the strategy and to seek
input for program design and implementation.
EPA's Contaminated
Sediment Management
Strategy
EPA's Contaminated Sediment Management Strategy utilizes a cross-
program policy framework to promote consideration and reduction of
ecological and human health risks posed by sediment contamination. The
strategy advocates cross-program coordination, as well as a watershed
approach, to prevent and remediate existing sediment contamination and
to prevent future contamination. Actions required to manage legacy
contaminated sediment sites as well as sites with existing discharges,
include source control, pollution prevention, and remediation.
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Table 6. Current Domestic and International Efforts Targeting HCB (Continued)
Current Domestic and International Efforts Targeting HCB
Program
Description
Lakewide Management
Plans (LaMPs)
The U.S. and Canadian governments agreed to develop LaMPs for each of
the five Great Lakes under Annex 2 of the 1987 Great Lakes Water Quality
Agreement. The purpose of the LaMPs is to assess critical pollutants as
they relate to the impairment of beneficial uses of the Great Lakes and to
develop measures to restore beneficial uses where they have been
impaired. HCB has been identified as a critical pollutant in the Lake
Ontario and Lake Superior LaMPs, each of which is in a different stage
with respect to its lakewide management plan. As part of the Lake
Superior LaMP, a Binational Program to Restore and Protect the Lake
Superior Basin was announced in 1991. One of the goals of this program
is to achieve zero discharge and emissions of persistent toxic pollutants,
including HCB, in the Lake Superior Basin.
Remedial Action Plans
(RAPs)
The Great Lakes RAP program originated from a 1985 recommendation
made by the International Joint Commission's Great Lakes Water Quality
Board and was formalized in the 1987 amendments to the GLWQA. The
aim of RAPs is to restore beneficial uses in 43 Areas of Concern (AOCs)
identified in the Great Lakes Basin where beneficial uses or the area's
ability to support aquatic life have been impaired. Through the RAP
program, Canada and the U.S. are committed to cooperating with state
and provincial governments to incorporate a systematic and
comprehensive ecosystem approach to address critical pollutants, to
restore beneficial uses, and to ensure that the public is consulted in all
actions undertaken to develop and implement RAPs for designated AOCs.
HCB is suspected of contributing to use impairments in some AOCs.
Pesticide Clean Sweeps
Pesticide Clean Sweeps are waste pesticide collection and disposal
programs that provide a means of collecting and disposing of accumulated
agricultural pesticides. Although pesticide uses for HCB were canceled in
1984 and remaining stocks were allowed to be used, data from Minnesota
Clean Sweeps have indicated that unused stocks of HCB have recently
been collected in that state.
Draft Pesticide
Registration (PR) Notice
EPA has issued a draft Pesticide Registration (PR) Notice to
manufacturers, producers, formulators and registrants of pesticides
(USEPA, 1999). The notice provides guidance to the registrant for
improving the clarity of labeling statements in order to avoid confusing
directions and precautions and to prevent the misuse of pesticides.
Improved product labeling statements are intended to clearly identify what
is required of the user to handle and apply a pesticide safely. This may
reduce HCB emissions and exposure through proper storage,
transportation, handling, pre-application activities, mixing and loading,
worker notification and worker protection, application, post-application
activities and disposal.
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Table 6. Current Domestic and International Efforts Targeting HCB (Continued)
Current Domestic and International Efforts Targeting HCB
Program
Description
International Programs
UN ECE Convention on
Long-Range
Transboundary Air
Pollution (LRTAP)
protocol
In February 1998, under the United Nations' Economic Commission for
Europe Long Range Transboundary Air Pollution (LRTAP) Convention, 43
countries completed negotiations on a regional Persistent Organic
Pollutants (POPs) protocol. The LRTAP Protocol sets a framework for
controlling, reducing, and eliminating discharges, emissions, and losses of
persistent organic pollutants, including HCB.
United Nations
Environment Program
(UNEP) Persistent
Organic Pollutant (POP)
The U.S. and member countries are currently working toward the
development and signing of an international legally binding agreement on
the control and reduction of persistent organic pollutants (POPs), including
HCB, through UNEP POPs negotiations. As the agreement currently
stands, member countries will be required to identify and quantify emission
sources for all listed POPs, develop action plans for reduction, and make
information available to the general public.
North American
Agreement on
Environmental
Cooperation Sound
Management of
Chemicals Program
The Working Group of the Sound Management of Chemicals Program has
approved HCB as a candidate substance for the development of a North
American Regional Action Plan. The North American Working Group on
the Sound Management of Chemicals was called for in Council Resolution
#95-5, developed under the authority of the North American Agreement on
Environmental Cooperation (NAAEC). Consistent with Council Resolution
#95-5, the duties of the Working Group involve establishing how the
Governments of Canada, Mexico, and the United States will cooperate to
improve the sound management of chemicals in North America, giving
priority to the management and control of substances of mutual concern
that are persistent, bioaccumulative and toxic, but also allowing for
cooperation on a broader scale for the sound management of chemicals in
the three countries.
Arctic Monitoring and
Assessment Programme
(AMAP)
HCB is recognized as one of the POPs in need of greater monitoring and
control in the Arctic under the Arctic Monitoring and Assessment
Programme (AMAP). AMAP was established in 1991 to implement
components of the Arctic Environmental Protection Strategy (AEPS)
adopted by eight Arctic countries including the United States. In support of
AMAP recommendations to assess health impacts of POPs and heavy
metals in the Arctic, EPA and the National Center for Environmental
Health are jointly funding a project to monitor selected heavy metals and
POPs, including HCB, in umbilical cord blood and maternal blood of
indigenous groups in the Arctic.
25
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Table 6. Current Domestic and International Efforts Targeting HCB (Continued)
Current Domestic and International Efforts Targeting HCB
Program
Description
Monitoring Efforts
Integrated Atmospheric
Deposition Network
(IADN)
IADN is a joint monitoring network established by the U.S. and Canada in
response to the Great Lakes Water Quality Agreement to address issues
concerning airborne contaminants in the shared Great Lakes basin. IADN
is designed to assess the magnitude and trends of atmospheric deposition
of toxic substances to the Great Lakes and, where possible, to determine
sources of atmospheric pollutants. Among other toxic chemicals, IADN
currently monitors the atmospheric deposition of HCB.
CAA §112(m) program,
Atmospheric Deposition
to Great Lakes and
Coastal Waters (Great
Waters Program)
The 1990 Amendments to the CAA include Section 112(m), Atmospheric
Deposition to Great Lakes and Coastal Waters, to establish research,
reporting, and potential regulatory requirements related to atmospheric
deposition of hazardous air pollutants (HAPs) to the "Great Waters".
EPA's Great Waters Program coordinates activities to address the
requirements of Section 112(m). HCB is one of 15 Great Waters
pollutants of concern. The "Great Waters" referred to in this program are
the Great Lakes, Lake Champlain, Chesapeake Bay, and specific coastal
waters designated through the National Estuary Program and the National
Estuarine Research Reserve System. EPA provides biennial Great
Waters Reports to Congress discussing the current scientific understanding
of atmospheric deposition and the health and environmental effects of
toxic pollution, as well as EPA programs to protect human health and the
environment.
USEPA National Study of
Chemical Residues in
Fish
Study design and peer review of EPA's National Study of Chemical
Residues in Fish have been completed. EPA will statistically evaluate the
incidence and severity of HCB and other chemical residues in fish, both
downstream from suspected problem areas and in background areas. EPA
will work with State Departments of Health and Environmental Protection
and will coordinate with state fish advisory programs. Sampling will begin
in fiscal year 1999 (FY99) and conclude in Summer 2001. Study results
will be available in FY02.
National Health and
Nutrition Examination
Surveys (NHANES)
Conducted by the Centers for Disease Control and Prevention's (CDC's)
National Center for Health Statistics, the National Health and Nutrition
Examination Surveys (NHANES) traces the health and nutritional status of
U.S. civilians. Human exposure to HCB will be measured and tracked in
NHANES 1999.
National Oceanic and
Atmospheric
Administration (NOAA)
Mussel Watch Program
The National Oceanic and Atmospheric Administration's (NOAA) Mussel
Watch Project has been using measurements of contaminants in mussel
and oyster tissues since 1986 to evaluate the status and trends in
contaminant levels in the nation's Great Lakes, estuarine, and marine
waters. Sites are visited approximately biennially for collection of animals
to be analyzed for a suite of over 70 contaminants, including HCB.
26
-------
Current Domestic and International Efforts Targeting HCB
Program
Description
FDA Pesticide Residue
Monitoring Program
(Total Diet Study)
HCB is analyzed in the Food and Drug Administration's (FDA) pesticide
residue monitoring program. To enforce pesticide tolerances set by EPA
for imported foods and domestically produced foods shipped in interstate
commerce, the FDA acquires incidence/level data on commodity/pesticide
combinations and carries out its market basket survey, the Total Diet
Study. FDA also samples and analyzes domestic and imported animal
feeds for pesticide residues. Results of FDA's Total Diet Studies are
available in published reports and on FDA's Internet web site. HCB is
among the pesticides found by methods used in the 1998 regulatory
monitoring program (http:\\www.cfsan.fda.gov).
Other efforts that affect emissions of HCB include campaigns at state and local levels,
voluntary industry initiatives, and changes in industry practices. Some examples include:
Community programs to use alternatives to pesticides and to reduce the use of
medical waste incinerators have been initiated in the Lake Superior Basin (WLSSD,
1998).
Significant improvements in the manufacturing process for chlorothalonil (a pesticide)
to reduce the content of HCB significantly.
Recommendations of best management practices in Ontario to reduce emissions from
the use of pentachlorophenol (containing HCB) in the wood preservation industry.
The decision by two major utility companies in Ontario to eliminate the use of PCP in
the treatment of utility poles, thereby reducing HCB emissions from wood
preservation (Benazon, 1999).
A commitment by Dow Chemical Company to reduce air and water emissions of
mercury and HCB by 75 percent by 2005.
6.0 CONCLUSIONS
Status of Knowledge Concerning Sources
Due to long-range transport and atmospheric deposition of HCB, sources of HCB releases
transcend the boundaries of the Great Lakes Basin. Sources in closest proximity to the Great
Lakes, such as the application of pesticides in and around the Great Lakes, likely have the greatest
impact on HCB loadings within the basin. However, there is evidence that sources far from the
27
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basin also contribute to HCB loadings in the basin, though more research on long-range transport
modeling of HCB is needed to gain a better understanding of this loadings pathway.
The relative significance of HCB sources to the Great Lakes Basin is uncertain. Table 7
summarizes the current status of sources of HCB in the U.S. Data show that, for 1990, the
highest emissions in the U.S. result from chlorinated solvents production, pesticides manufacture,
tire manufacture, cyclic crude and intermediate production, chemical manufacture of alkalies and
chlorine, and pesticide application. More recent data from the tire manufacturing industry suggest
that emissions from this sector are lower than previous estimations. Due to the scarcity of major
industrial sources of HCB within the basin, emissions from pesticide application may be a
dominant source of HCB to the Great Lakes Basin, with lesser contributions from industrial
sources outside the basin. Releases from residual sources for which emission estimates are not
available are also thought to contribute to HCB contamination in the basin. These include
releases from waste incineration and cement kilns, open trash burning, PCP-treated utility poles,
and sewage treatment plants.
Several chemical reporting mechanisms show that HCB continues to be released to the
environment. Air and water releases from pesticide and chemical manufacturing facilities have
been reported to TRI as recently as 1997, and these were reported with relatively high reporting
threshold requirements. The proposed lower reporting threshold requirements for 2000 may
generate a greater number of HCB releases being reported to TRI. HCB appears in various waste
streams reported to RCRA's Biennial Reporting System, particularly the wastes from industrial
chlorination processes. Releases of HCB from residual sources go unreported.
Although decreasing trends have been demonstrated for HCB levels in environmental
media of the Great Lakes over the last 10-20 years, the region remains an area of particularly high
contamination for fish and wildlife. HCB concentrations in mussels from the Great Lakes were
found to be more than five times higher than HCB levels in mussels from coastal waters of the
U.S. (Robertson and Lauenstein, 1998). Monitoring data from IADN stations in the Great Lakes
indicate that the net movement of HCB involves volatilization out of the water. Soils and
sediments at several sites in the Great Lakes Basin are also contaminated with HCB.
28
-------
Table 7. Summary of Current Status of Sources of HCB in the U.S.
Source Category
Chlorinated Solvents Production
Pesticides Manufacture
Pesticide Application
Tire Manufacturing
Cyclic Crude and Intermediate
Production
Chemical Manufacturing: Alkalies and
Chlorine
Miscellaneous Organic Chemicals
Production (MON - Continuous
Processes)
Chemicals and Allied Products
Manufacturing
Hydrochloric Acid Production
Utility Coal Combustion
Aluminum Degassing
Waste Incineration and Cement Kilns
Open Barrel Trash Burning
Wood Preservation
Sewage Treatment Plants
Status
SOCMI HON (40 CFR 63.100) rule will control organic HAP
emissions
Voluntary initiatives are being pursued through BNS
1997 TRI emissions: 5 Ibs to air, 26 Ibs to water
A recently finalized PAI rule will control HAP emissions
Voluntary initiatives are being pursued through BNS
Reduced HCB content in chlorothalonil will lower emissions
Alternative pest management programs discourage the use of
chemical pesticides
Industry expected to report zero emissions as a result of recent
testing
1997 TRI emissions: 14 Ibs to air
One manufacturing facility reported releases to TRI
1997 TRI emissions: 135 Ibs to air, 250 Ibs to water, 139 Ibs
injected underground
Dow Chemical, a major chemical manufacturer, has committed to
reduce HCB emissions by 75% by 2005
Miscellaneous Organic NESHAP (MON) limits emissions
Category may be included in Chemical Manufacturing: Alkalies
and Chlorine category
Current emissions unknown
Not included in most recent emissions inventory
Emissions from the use of HCE may be a concern at some small
secondary aluminum furnaces
Emissions expected to be reduced by MACT standards
Current emissions unknown
May be a concern in rural townships and tribal communities
Current emissions unknown
Ontario measures to lower emissions include implementing best
management practices and reducing the use of PCP to treat utility
poles
Current emissions unknown
HCB-contaminated ferric chloride may contribute to the problem
Regulations and Regulatory Gaps
Regulations are in place to control emissions from chlorinated solvents production and
pesticides manufacture, the two largest sources of national HCB emissions. Voluntary initiatives
in the pesticides industry have been shown to result in additional reductions of HCB in
29
-------
chlorothalonil, a commonly used pesticide. Similar voluntary efforts might prove successful in
lowering levels of HCB in other pesticides and in chlorinated solvents.
HCB emissions from other major source categories might also be reduced by voluntary
efforts, rather than through regulatory controls. For example, enhanced efforts to control or re-
route air emissions or effluent discharges from cyclic crude and intermediate production might
result in reduced release to the environment. Community programs encouraging the use of
alternatives to HCB-containing pesticides may help reduce HCB emissions from pesticide
application.
Actions and regulations have been promulgated to control emissions of toxic pollutants
from waste incineration and cement kilns. Although HCB is not a targeted pollutant, emissions of
HCB will likely be reduced as a result. For example, actions have been undertaken to reduce
mercury and dioxin emissions from medical waste incinerators by reducing the volume and
toxicity of waste incinerated. New regulations require controls on medical waste incinerators,
municipal waste combustors, cement kilns and lightweight aggregate kilns to limit organic
chemical and metals emissions. Because these actions and regulations are intended to reduce
organic emissions overall, reductions in HCB emissions are expected.
HCB emissions from residual sources are variously controlled. Statutes banning open
trash burning exist for some states and municipalities, but it is difficult to enforce these statutes.
There may be a need for increased regulations and enforcement or for increased education and
recycling opportunities. PCP containing HCB is used to treat utility poles. Whether methods
exist to contain HCB emissions from PCP spills and releases during wood treatment is not known.
Also, there are no restrictions on the use of old utility poles and railroad ties treated with PCP for
residential purposes. Sewage treatment plants may take measures to determine the source of
HCB discharges to their facility, and NESHAPs for sewage sludge incinerators may control HCB
emissions. However, there are no limitations on the content of HCB in ferric chloride used in
waste water treatment.
Although water and waste regulations are in place, release to these media still occurs.
Hazardous wastes generated by chlorination processes are regulated under RCRA and are subject
to pre-treatment standards prior to landfill disposal. However, there is the potential for HCB to
leach from contaminated landfills. Water releases are regulated under the NPDES permit system,
but TRI reports indicate that HCB has been discharged for the past several years from industrial
facilities in the alkalies and chlorine and agricultural chemical sectors.
30
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7.0 REFERENCES
Agency for Toxic Substances and Disease Registry, U.S. Public Health Service, (1999) ATSDR's
Toxicological Profiles on CD-ROM, CRCnetBase.
Benazon Environmental Inc. (1999) Hexachlorobenzene Emissions/Releases Inventory for the
Province of Ontario, 1988, 1998, and 2000 Draft Report. Submitted to Toxics Prevention
Division, Environmental Protection Branch, Environment Canada, April.
Brody, T.M., Furio, B.A., and Macarus, D.P. (1998) Agricultural Pesticide Use in the Great
Lakes Basin: Estimates of Major Active Ingredients Applied During 1994-1995 for the Lake Erie,
Michigan, and Superior Basins, U.S. Environmental Protection Agency, Region 5, June 15.
Chu, Paul (1998). Representative of Electric Power Research Institute, personal communication.
For this study, the results of three measurements were averaged.
Cohen et al. (1995) Quantitative Estimation of the Entry of Dioxins, Furans, and
Hexachlorobenzene into the Great Lakes from Airborne and Waterborne Sources, Center for the
Biology of Natural Systems, Flushing, NY.
Cummings, Anita (1999) OSW, EPA, personal communication.
Dann, T. (1997) Monitoring of Persistent Toxic Substances in Ontario-Great Lakes Basin,
Environment Canada Technology Development Directorate, Environmental Technology Centre,
October.
Huestis, S.Y., Servos, M.R., Whittle, D.M., and D.G. Dixon (1996) Temporal and Age-Related
Trends in Levels of Polychlorinated Biphenyl Congeners and Organochlorine Contaminants in
Lake Ontario Lake Trout (Salvelinus namaycush). J. Great Lakes Res. 22(2):310-330.
IADN Scientific Steering Committee (1998) Technical Summary of Progress under the Integrated
Atmospheric Deposition Program 1990-1996, U.S./Canada IADN Scientific Steering Committee,
January.
Jensen, Janice (1999) OPP, EPA, personal communication.
Maxwell, Bill (1999) EPA Emissions Standards Division, personal communication.
Nash, R.G. and Gish, T.J. (1989) Halogenated Pesticide Volatilization and Dissipation from Soil
under Controlled Conditions, Chemosphere 18:2353-2362.
Pope, Anne (1999) EPA, personal communication.
31
-------
Robertson, A. and Lauenstein, G.G. (1998) Distribution of Chlorinated Organic Contaminants in
Dreissenid Mussels Along the Southern Shores of the Great Lakes, J. Great Lakes Res.
24(3):608-619.
Schmidt, R., Scheufler, H. Bauer, S., Wolff, L., Pelzing, M., and Herzschuh, R. (1995)
Toxicological investigations in the semiconductor industry: III: Studies on prenatal toxicity
caused by waste products from aluminum plasma etching processes, Toxicology and Industrial
Health 11(1):49-61.
Sound Management of Chemicals (SMOC) (1998) Nomination Dossier for Hexachlorobenzene,
Submitted by Canada to the Working Group of the Sound Management of Chemicals (SMOC),
April 22.
United States Environmental Protection Agency, "Evaluation of Emissions from the Open
Burning Of Household Waste in Barrels," Office of Research and Development, U.S.
Environmental Protection Agency. EPA 600-R-97-134b, November 1997.
United States Environmental Protection Agency, "1990 Emissions Inventory of Section 112(c)(6)
Pollutants: Polycyclic Organic Matter (POM), 2,3,7,8-Tetrachlorodibenzo-p-dioxin
(TCDD)/2,3,7,8-Tetrachlorodibenzofuran (TCDF), Polychlorinated Biphenyl Compounds
(PCBs), Hexachlorobenzene, Mercury, and Alkylated Lead," Emission Factor and Inventory
Group and Visibility and Ecosystem Protection Group, U.S. Environmental Protection Agency.
April 1998.
United States Environmental Protection Agency, "Pesticides; Draft Guidance on
Mandatory/Advisory Labeling Statements," Federal Register, pp. 29641-29643, August 4, 1999
(Volume 64, Number 149).
U.S. National Library of Medicine, Hazardous Substances Data Bank (HSDB). Issue: 99-2, May,
1999.
Westberg, H.B., Selden, A.I., and Bellander, T. (1997) Emissions of some organochlorine
compounds in experimental aluminum degassing with hexachloroethane, Appl. Occup. Environ.
Hyg. 12(3): 178-183.
Western Lake Superior Sanitary WLSSD, "Zero Discharge Pilot Project," Final Report, Western
Lake Superior Sanitary WLSSD, 1998.
32
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APPENDIX A
Appendix A contains information on HCB releases available from several federal and state
reporting systems. Federal and state agencies collect information on HCB releases as part of
broader programs designed to meet reporting requirements for multiple substances. It is important
to keep in mind that each data set must be interpreted separately due to differences in reporting
requirements and the types of information collected. Where information is available, data are
organized by Standard Industrial Classification codes (SIC codes). This structure offers a uniform
method to identify industrial sectors. The first two digits of an SIC code identify major industrial
sectors. The full four digit code allows more specific identification of industry type. Even with this
detailed breakdown, variation exists within a given SIC code. For a complete list and description
of SIC codes, as well as the specific industrial processes covered by each code, refer to the
Standard Industrial Classification Manual.
Table A1. Trends in HCB Releases from 1990 to 1997 by SIC Code from TRI
SIC
Code
1990
1991
1992
1993
1994
1995
1996
1997
Air Fugitive or Non-Point Emissions
2800
2812
2865
2879
2869
3241
2
347
829
80
-
-
88
192
21
248
0
-
42
3,852
4
240
0
-
-
48
0
247
9
-
-
64
12
247
0
23
-
216
15
246
0
-
-
96
14
5
0
-
-
106
14
5
0
0
Air Stack or Point Air Emissions
2800
2812
2865
2879
2869
3241
100
102
1
7
-
-
120
160
1
11
0
-
1
332
0
0
0
-
-
331
0
0
1
-
-
112
0
0
0
0
-
89
0
0
0
-
-
105
0
0
0
-
-
29
0
0
0
0
Disposal
2800
2812
2869
2879
4
7
-
33,981
-
7
-
1,064,786
5
1
-
28,374
-
7
250
647,753
-
-
-
940,476
-
-
-
6,975
-
8
-
23,441
-
6
-
12,032
A-1
-------
Table A1. Trends in HCB Releases from 1990 to 1997 by SIC Code from TRI (Continued)
SIC
Code
1990
1991
1992
1993
1994
1995
1996
1997
Land Releases
2800
2812
2865
2869
2879
3241
0
0
0
-
0
-
0
1
0
0
1
-
0
0
0
0
0
-
-
0
0
0
0
-
-
0
0
0
0
-
-
0
0
0
0
-
-
0
0
0
0
-
-
0
0
0
0
0
Underground Injection
2800
2812
2865
2879
2869
3241
0
220
0
0
-
-
0
60
0
0
0
-
0
794
0
0
0
-
-
548
0
0
0
-
-
204
0
0
0
0
-
480
0
0
0
-
-
-
-
-
-
-
-
-
-
-
-
-
Water Releases
2800
2812
2865
2869
2879
3241
9
92
0
-
23
-
1
98
0
0
12
-
32
190
0
0
5
-
-
390
0
80
6
-
-
248
0
0
21
0
-
6,344
0
0
114
-
-
250
0
0
24
-
-
250
0
0
26
0
Table A2. HCB Concentration Data from IADN Master Stations 1992-1994 Annual
Averages
Year
1992
1993
1994
Superior
Precip
(ng/L)
0.10
0.37
0.10
Particle
(pg/m3)
0.20
3.91
0.20
Gas
(pg/m3)
98.0
68.0
70.2
Michigan
Precip
(ng/L)
0.06
0.25
0.06
Particle
(pg/m3)
0.10
3.56
0.10
Gas
(pg/m3)
120
87.4
77.5
Huron
Precip
(ng/L)
0.13
0.18
0.08
Particle
(pg/m3)
NA
NA
NA
Gas
(pg/m3)
0.05
31.1
28.2
Erie
Precip
(ng/L)
0.04
0.15
0.04
Particle
(pg/m3)
0.20
4.18
0.20
Gas
(pg/m3)
80.0
102
83.5
Ontario
Precip
(ng/L)
0.30
0.11
0.04
Particle
(pg/m3)
0.10
NA
NA
Gas
(pg/m3)
130
33.8
43.3
A-2
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Table A3. Summary of HCB Reporting Data in Great Lakes States
Reporting
System1
BRS
PCS
TRI
Number of Facilities Reporting
Total
69
60
0
IL
5
14
0
IN
7
2
0
Ml
11
4
0
MN
2
1
0
NY
5
0
0
OH
29
7
0
PA
9
0
0
Wl
1
32
0
1 Data is the most current available for each reporting system:
Biennial Reporting System (BRS): 1995
Permit Compliance System (PCS): 1995-1999
Toxic Chemical Release Inventory (TRI): 1997
Table A4. Sites Within EPA Region 5 Currently on the Final NPL (Superfund) with HCB
Detected as a Contaminant of Concern
1
2
3
4
5
6
7
8
9
10
11
Site Name
Woodstock Municipal Landfill
American Chemical Service, Inc.
Reilly Tar & Chemical (Indianapolis Plant)
Metamora Landfill
Ott/Story/Cordova Chemical Co.
Rasmussen's Dump
Thermo-chem, Inc.
Chem-dyne
Fields Brook
Skinner Landfill
Summit National
City
Woodstock
Griffith
Indianapolis
Metamora
Dalton Township
Green Oak
Township
Muskegon
Hamilton
Ashtabula
West Chester
Deerfield Township
State
Illinois
Indiana
Indiana
Michigan
Michigan
Michigan
Michigan
Ohio
Ohio
Ohio
Ohio
A-3
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