Document GzBempdnZw0q5347pydV7BLer

FILE: PVC Land Disposal vOI(x K CULf* c-**ntammmfuiiM-N *'LIUK H AICOl D M*CAf*<Ul MAftTii* w gi*covei JO-N uftD CAftOLC c NAHA'S * MO*QC JOnh t Ou#tC- IMIALC* ft rvv/lNQTO LAWaiMCt Ak*lN CON*** U HO**l TlIBCueC JOWKI fQV ***** Aavn a C OOUOcASJASAC^T A ftUlftC* BUIICLk H 'O* JAN M WAMflt-CC* UfMC INOCL MCCLCH tUIAN T CONTI SUSAN j. OLUMaAr c. NATCS SANOAa v OCNMIS PAATSAICM* LWEVINS s caai TAjrrur QAVlD m, jCTTN AOMrrCO IN ViANA OHI.* *AOMtTTCO IN '|HH|*IVAHU ONLY LAW OFFICES Keller and Heckman USO 17'* STREET, K. W. SUITE lOOO WaSHINGTON, D.C. 8003 (202) 050-5000 September 30, 1986 SC*KNTiriC TA" OANifLS OlXLf* OUWA*0 t OOMCN eAiC9V MCOCH TK(x A 99991 *! ! ?( CA9L1 AD09C99 "HCLMAN WfllTCft'ft OlMCCT 1AC NVMftCA (202)956-5641 Joseph C . Ledvina Vista Chemical Company 15990 North Barker's Landing Road Houston, Texas 77224 Re: PVC Land Disposal Survey Dear Joe: fii-otiVti) OCT j 1986 DR.R.T. GOTTESMAN In keeping with our discussion last week, enclosed is a revised and final copy of the results of the Land Disposal of Polyvinyl Chloride (PVC) Survey. I understand that you will be using this as a basis for a presentation to the Vinyl Chloride Safety Association in October. If you have any comments or questions or if I can be of any assistance, please let me know. Cordially yours, Peter L. de la Cruz Enclosure cc: W. C. Holbrook Robert D. Luss, Esq. Charles E. O'Connell Lewis R. Freeman, Jr. Roy T. Gottesman, Ph.D. VVV LAND DISPOSAL OF POLYVINYL CHLORIDE This report presents the results of a survey conducted by the Health, Safety and Environment Committee of the Vinyl Institute, a division of the Society of the Plastics Industry, Inc. Survey forms were mailed in June 1986 to members of the Vinyl Institute and the Vinyl Chloride Safety Association. The responses were combined and presented in the same sequence as the initial survey. Twenty-nine responses were received from 23 companies worldwide. Due to the inapplic ability of the survey to responders having only vinyl chloride monomer facilities and because respondents frequently left questions unanswered, responses to individual questions do not total 29. f VVV GOGOG44S7 Participants in PVC Disposal Survey 1. Air Products and Chemicals, Inc. 2. Aiscondel Sociedad Anonima 3. BFGoodrich Co. 4. Borden Chemical 5. CertainTeed Corporation 6. Dow Chemical Company 7. Dutch State Mines 8. Formosa Plastics Corporation Delaware 9. Georgia - Pacific 10. Mitsui Toatsu Chemicals, Inc. 11. Norsk Hydro 12. Occidental Chemical Corporation 13. Pequiven 14. Petroquiraica Colombians S.A. 15. PPG Industries, Inc. 16. Societe Artesienne de Vinyle 17. Solvay & Cie. 18. Tenneco 19. Vista Chemical Company 20. Vulcan Chemical 21. Unknown - 3 f VVV 000004488 2 1. Have PVC Hastes From Your Plant Been Land Disposed? Yes -- 23 No -- 2 Do not know -- 0 If Yes, Generally Describe the History of Disposal. Land Disposed, Describe How Haste Has Handled. If Not The majority of respondents indicated that PVC waste has been land disposed both off-site (10 responses) and on-site (5 responses). Two respondents indicated that suitable PVC waste is sold as off-grade or low quality PVC for suitable applications. The non-duplicative portions of individual responses follows. PVC wastes are placed with municipal garbage for sub sequent incineration. We always have utilized land disposal for PVC solid waste from plant production and wastewater treatment opera tions. Waste was generally commingled with municipal waste and placed into municipal landfills. One wastewater treatment pond filled with waste PVC was covered with dirt and seeded. PVC waste resins were placed in a municipal landfill for approximately 28 years. This material was collected in a primary wastewater settling lagoon and in small settling pits. Collected and disposed of in landfill; 44 tons in 1985. Large particles separated from other resin are collected in bins, then loaded onto a truck and dumped at an on-site landfill. vvv 0000044B9 3 Land disposal on-site in registered disposal area (Class III) . It has been classified as inert and disposed of in places designated for that purpose. From 1961-78, reactor scrapings and dry scrap to commercial facility; oversize and wastewater treatment plant sludges to on-site sludge ponds, dried, mixed with soil and used for on-site fill. From 1978-85, all scrap, oversize and wastewater sludges to on-site drying ponds. From 1985 to present, all wastes with VCM less than 400 ppm dried and disposed in commercial facility. All greater than 400 ppm segregated and dried on-site. PVC from settling ponds is dipped out on a one-to-two year basis. This PVC is placed in clay-lined cells in the landfill. Emulsions wastewater goes through primary treatment where solids are removed by flocking with ferric chloride and lime. The resulting sludge is placed in clay-lined cells in the landfill. Wet waste from efflu ent treating system goes onto sand filter beds; periodically th ese are dug out and this is transported off-site. Sand leach ing beds have leachate collection, Dry waste not going through effluent treating is sold. Generally, PVC solids were collected at various sources, such as screen tailings, reactor clean-outs, and effluent sludge filter cake and sent to various county landfill sites. PVC solids were also accumulated over periods of time in various earth lagoons and aeration lagoons, which were periodically excavated and either sold as off-grade PVC or sent to landfill sites. One large earth lagoon filled with approxi mately 25,000 cubic yards of PVC was capped with a synthetic liner, covered with earth and vegetated on a site adjacent to the plant in the late 1970's. Small quantities of PVC slurry and/or PVC agglomerates have been disposed in off-site waste disposal lagoons since 1967. Same lagoons are being used by other chemical plants also for waste disposal. History of disposal: From 1968 to 1980 -- Area A lagoons; from 1981 to 1986 -- Areas B lagoons. Wastewater with PVC suspension is retained in an open air concrete reservoir in which PVC forms a sediment. Once a VVV 0000QA490 4 year we recover this PVC, dry it and sell it for very low quality level applications. Water from this reservoir is treated in the wastewater treatment unit of the factory and reused in suitable units of the process. Scraps and oversize particles are recovered directly from the kettles and dryer and also sold as a low quality PVC. PVC present only in wastewater pumped from poly merization unit (reactor and storage tanks cleanup water) to decantation basins. PVC wastes, such as oversized powder, spills, etc. are sold to the customers as off-grades. PVC wastes have been rarely land disposed -- only over sized particles which were directly pumped out of the reactors. All other wastes are bagged (PE liner) and sold as such. A total of 23 acres have been used in 43 years. First 17 acres filled by 1977. Use of six adjoining acres under same state permit should last 10 years more to 1997. The company has permit responsibility except for limited previous owner's liability. An aircraft company opened landfill 1943 as U.S. Government war plant. Government leased to previous owner 1945, then sold to them 1950. Production stopped early 1980; previous owner sold to present owner December, 1980. Landfill used as open dump to 1970--liquids, oils, no cover, etc. State began regulating then and granted Permit 1973 as Ind. Waste Disposal Site. Perhaps 70% of volume overall is from 30 years flyash and 37 years PVC sludge disposal. Many scrap tires also buried up to 1970. Permit condition is requirement to collect and treat leachate in event of degradation of groundwater quality. Groundwater quality is monitored by State required quarterly testing of samples from four shallow wells on river side of landfill and wastewater lagoons. Test protocol does include organics--no apparent pollution by prescribed protocol in State evaluation of results. Monitoring will continue as required. The company conducted 1-1/2 years comprehensive study sampling 15 deep and shallow wells around landfill-- tested for 129 EPA Priority Pollutants: Many organics, metals, etc. Some organics found at low levels in some wells, but no pollution in the company's interpretation. The company will continue its program on reduced scale. No statute yet limiting designated pollutants in groundwater generally? only where drinking water aquifer is identified. EPA and states are imposing remedial measures on ad hoc basis. The plant landfill VVV 000004491 5 groundwater has not been identified as affecting a drinking water supply. The Plant has deposited waste PVC as sludge and scrap on an on-site landfill for some 40 years. Currently, this is about 200 wet tons per month of 50% solids sludge plus 12 dry tons per month of scrap. The sludge contains about 175 ppm of VC and 400 ppm of TCE, both on the wet basis. We have very little and unreliable data on the scrap. The quantity of sludge rose from a low level in the 1940's when the Plant was small to a peak in the 1960's of perhaps four times the current rate. With the onset of regulatory activity in the 1970's, the volume has steadily declined. Scrap quantities followed this same trend. VC and TCE concentrations, however, were probably considerably higher right from the start and only slowly declined until the regulatory push in the 1970's. In 19831984, a comprehensive groundwater study was conducted over 11/2 years. Six of fifteen wells sampled around the landfill were analyzed for VC and TCE, All were found to have less than 5 ppb of either contaminant. Four of these wells were 20 ft. deep and two were 125 ft. deep. There is no clear-cut explanation of the fate of all the VC and TCE placed in the landfill over the years--biodegradation, migration, etc. How ever, both government and company believes that these pollutants do not leave company property. This is because of the continuous pumping of six deep (300-400 ft.) process water wells on the site for supply to the PVC production process. Since the normal rainfall in the area is not enough to recharge the deep water layer being pumped at about 600 GPM, the short fall is being made up through a cone of depression from the nearby river and aquifers off-site around the Plant boundaries. This is confirmed by TCE analyses of the deep wells showing 20100 ppb, but not by VC concentrations: Less than 1 ppb. ! vVV 000004492 2. Has Disposal On: 6 Plant Property -- 16 Off-Site -- 3 Municipal Landfill -- 9 Commercial Waste Disposal Facility -- 9 Not Applicable -- 2 ^ ooooo^3 * 6 ^ 0 0 0 0 0 AAA Describe the Wastes That Were (Or Are) Being Land Disposed at Bach of These Sites. The majority of respondents indicated that suspension resin is most frequently land disposed. Wastewater and oversize particles are the most common waste type destined for land disposal. The earliest date reported sposal was 1940. Resin Type Waste Type Amount Residual VCM Level Dates of Disposal Suspension Compound N/A Suspension PVC Suspension PVC Suspension & emulsion Suspension Suspension Mass resin Suspension, dispersion, latex, mass, compounds Suspension Oversize, wastewater sludge, contamination Contamination Unknown Unknown Ove r size particles Regular particles Wastewater sludge 200.000 lbs./yr. 300.000 lbs./yr. 300,000 lbs./yr. Oversize, wastewater sludge Wasterwater sludge 10.000 lbs./wk. 50.000 lbs. Oversize particles 44 tons Fines, lumps, floor sweepings 12,000 kg/mo. Reactor cleanings, "lots & lots" filter cleanings, floor sweepings, drummed latex scrap, compound scrap, screenings, wastewater treatment sludge, coarse charges, etc. Oversize material to municipal landfill 175 tons/yr. Unknown Unknown 1-400 ppm 1-400 ppm less than 10 ppm RVCM range 0-10,000 ppm in the old days-today except for infrequent coarse charges the RVCM is always less than NESHAPS allowable. 700 ppm Since 1960 Since 1960 1980-Present 1980-Present 1980-Present 2 per week 2 per year 1985 1963-Present i -o I Compound Scrap to municipal landfill 50 tons/yr. Suspension Resin from settling basin to commercial waste disposal facility 25 tons 45 tons 45 tons Suspension Oversize particles, burned or contaminated product, resin settled from wastewater 30 yd.3/mo. Suspension Very fine particles from centrifuge 20 tons/ yr. Suspension Wasterwater sludge 30 tons/yr. Dispersion PVC sludge from cleaning dryer 20 tons/yr. PVC production, disper sion homopolyme r and copolymer, suspension homopolymer and copolymer, PVC calendaring PVC sludge PVC "scrap" Suspension Wastewater sludge 2400 tons/yr. 50% H2O 144 tons/yr. 6713 dry tons Suspension Wastewater sludge 3308 dry tons Suspension Wastewater sludge 2395 dry tons Suspension Wastewater sludge 12,416 dry tons Less than 500 ppm 175 ppm Nil to several 1000 ppm 4 ppm avg. (16 samp.) 29 ppm avg. (15 samp.) 1963-Present 1986 1884 1983 Ongoing Since 1947 Since 1947 Late 1979-1984 1985 1986-Present 1979-Present QbV^OOOOO AAA Suspension & emulsion Suspension 6 emulsion Suspension & emulsion Suspension & emulsion Bulk PVC Suspension Suspension Oversize particles, reactor cleanings and waste Wastewater sludge Oversize particles, reactor cleanings and wastewater sludge Oversize particles, reactor cleanings and wastewater sludge Powder and crust Oversize particles, sweeps, lumps, pond dredgings Dry scrap, sweepings Suspension Paste Wet scrap, oversize, wastewater sludge Dry scrap, sweepings Suspension Suspension Paste Scrap, oversize, wastewater sludge Scrap, oversize, wastewater sludge Dry scrap, sweepings about 25 mm lbs. more than 75 mm lbs. about 5 mm lbs. 80,000/yr. about 4000 tons 30.000 lb./mo. approximately 40.000 lb./mo. approximately 30.000 lb./mo. approximately 80.000 lb./mo. approximately 65.000 lb./mo. approximately 10.000 lb./mo. approximately ---------Less than 1 ppm4000 ppm Less than 1 ppm to Less than 2000 ppm 5 ppm--1000 ppm Less than 10 ppm ---------- ---------- ------------------- Less than 400 ppm Less than 400 ppm Late 1960's 1976-1979 1970's to 1st half of 1985 1985-Present 1975-Present 1975-1985 1961-1978 1961-1978 1978-1985 1978-1985 1985-1986 1985-1986 VVV 0 0 0 0 0 4 4 9 7 Suspension and some PVC latex Vessel washouts, oversize, spills Suspension Suspension, dispersion Suspension Dispersion Suspension Dispersion Compound Suspension Suspension 6 emulsion Emulsion Suspension Suspension Wastewater sludge Oversize particles wastewater sludge Oversize particles, wastewater treatment Has to be settled before disposal Sludge; oversize particles Oversize particles Oversize particles Oversize particles Wastewater sludge Pebbles Wastewater sludge, reactor cleaning lumps Wastewater sludge, reactor cleaning lumps Variable -0.1-1.0 mm lb./yr. 300 tons/yr. -- About 200 tons/ yr. About 10 tons/ yr. 1000-1500 tons/ yr. 50-70 tons/yr. 200-300 tons/yr. 55 tons 1 g/liters -- 200 kg/day 200 kg/day 100 ppm average 20 ppm -- Not measured Not measured 50 ppm down to 1 ppm Less than 10 ppm 100 ppm to 1 ppm 500 ppm About 1 ppm About 1 ppm Less than 5 ppm 1956-1984 1972-1984 -- Since 1974 Since 1974 1950-present 1940-present 1970-present Last 3 years At present At present 1967-1980 1901 to prese 11 4. Were the Residual VCM Levels in These Waste Measured or Estimated? No -- 6 N.A. -- 2 Measured -- 6 Estimated -- 9 The following are typical comments: Some measurements were made in 1981. The residual VCM of the suspension oversize material is based on 1986 measurements. Some measurements were made but with very few analyses of "scrap" and this 10 years ago. The VCM levels have been measured for all PVC waste disposed of since 1984. Measurements were done intermittently before that time. Often measured at less than 5 ppm. The residual VCM in the PVC waste is estimated. How ever, the PVC is stripped to below 400 ppm, presently averaging about 100 ppm. Some samples of the PVC waste show as low as 1.0 ppm VCM. The residual VCM in the emulsions wastewater is estimated. However, the emulsions are stripped to less than 10 ppm and all wastewater with greater than 10 ppm is stripped to less than 10 ppm VCM. f vvv 000004498 12 5. Do any o the Land Disposal Facilities Have Groundwater Monitoring? Describe the Groundwater Monitoring System. Number of Wells, Depth, Proximity to Waste, Btc. When Were the Wells Installed? Unknown -- 2 N.A. -- 2 Yes -- 3 No -- 9 The majority of respondents indicated that the land disposal facility utilized by the plants are equipped with monitoring wells. The mid-1970*s appears to be the earliest installation time for a monitoring system. Repesentative comments follow. Five monitoring wells approximately 45 ft. deep are located around the circumference of the landfill. The wells were installed prior to the startup of the landfill in 1980. They are located 300 - 1,000 ft. from ,the cells containing the PVC and the emulsions wastewater sludge. Groundwater samples from the wells are taken and analyzed each six months. How ever, the samples have not been analyzed for VCM. Seven groundwater monitor wells are installed around the landfill. The wells are 80-100 ft. deep and were installed in 1985. The wells are located within 100 ft. of landfill waste. Under a state permit, samples are taken from four shallow wells installed in 1977, at a depth of 12-20 ft. (A map depicting the locations of the landfill and lagoons and the quarterly and annual test protocols are attachments A to this survey.) VVV 000004499 13 Eleven wells were installed about 1980 and vary from 40-80 ft. deep, all outside buffer zone. Most are located 100-200 ft. from the waste although some are up to 1000 ft. away. Approximately 20 wells were installed on the outside perimeter down to bedrock, about 60-70 ft. deep. One facility has sludge drying beds, lined with leachate collections and returns. There are approximately six wells, 15-20 ft. deep, immediately adjacent to walls and installed in 1974. At a second facility with unlined sludge drying ponds, approximately six wells, 12-25 ft, deep, sur rounding the ponds were installed in the early 1980's. In addition, at a commercial landfill, 8 wells {4 deep and 4 shallow) are located on perimeter of fill. PVC plant site has groundwater monitoring that includes approximately 33 observation wells penetrating to the first aquatard approximately 60 ft. below ground level. The wells cover an area of approximately 800 acres. Wells are directly adjacent to waste sites and generally down gradient of the waste sites. Most wells were installed in 1982 and 1984. Three other locations all have monitoring wells, but we are not familiar with details. Off-site No. 1 -- 3 wells, installed 1978, 1 upgradient, 2 down; sampled and analyzed quarterly; average well depth 45 ft. Off-site No. 2 --7 wells (6 at 80 ft. and 1 at 30 ft.); installed 1984; sampled and analyzed quarterly. On-site -- 4 wells installed 1985, 1 upgradient, 3 down. Area A has 10 wells; Area B has 3 wells, 15-20 meters deep, at a distance of approximately 25 meters from the waste. f VVV 000004500 14 6. Has VCM Been Detected in the Landfill? If So, At What Concentration and When Was It First Detected? Unknown -- 2 N. A. -- 2 No -- 12 Some VCM has been detected in landfills. However, the majority of respondents indicated that either no monitoring has been conducted or, when the landfill was sampled, no VCM was detected. Sample responses follow. No monitoring for VCM at landfill has been done. No measurement available. There is no clear-cut explanation of the fate of all VC and TCE placed in the landfill over the years --biodegradation, migration, etc. Detected perchlorate. The landfill was sampled for VCM. The water below the landfill was sampled and no VCM was detected. Facility Is 0-1.2 ppm. Well casing is PVC pipe. Facility 2s 0-5 ppb. Facility 3: 0-17 ppb. VCM has been detected in the groundwater at the PVC plant site. Levels as high as 2.6 ppm of VCM have been detected. First detected in March 1980. In a recent government survey, no VCM was found. r VVV G0000*501 15 7. Do You Have Any Information on VCM in Air Near Land Disposal Facilities. Provide Concentrations and Details on Monitoring System. (This Includes Any Land Disposal Facility Not Just Those With PVC Manufacturing Waste.) Have No Information -- 15 N.A. -- 1 The majority of respondents indicated they have no information on VCM in air near landfills. Most respondents who have monitored the ambient air reported no detection of VCM. No VCM has been detected at local landfills. None detected. Ambient air is monitored. No trace on the auto sampled and analyzed detectors which are located at 50 meters from disposal point. Using handheld VCM detection equipment, sensitive to 1 ppm, VCM was nondetectable. In 1970's, took a few OSHA bag samples on person walk ing on top landfill? no VCM detected. Batelle did a study in the mid 1970's. We objected greatly to the methods and results. The South Coast Air Quality Management District (SCAQMD) in California has lots of information on this topic. We have done some monitoring over the years at landfill/truckdriver operations, and their exposure has always been less than OSHA limits. We are now starting a monitoring system for measuring ambient VCM. One of the controlled areas will be the wastewater treatment unit--land disposal facilities, but we have no data yet. f VVV 000004502 16 Monitoring systems: chromatography of land disposal area, including VCM and PVC plants wastewater. Average: 0.03 mg/m3, maximum: 0.1 mg/m^. I r yvv 00000*503 17 8, Provide Any Information You Have on the Stability of VCM in Groundwater. Does It Degrade? Does It Volatilize? Is VCM Bound to the Soil Particles? N.A. -- 1 Unknown -- 1 No Information -- 13 It does not bind strongly to sediment as is noted in the STAR document of 1975 and other EPA reports. VCM does volatilize readily, as is witnessed by the ease of air stripping and the presence of VCM around landfills, and it does degrade. However, the rate of degradation is considerably less than the rate of volatilization. I expect that most of it escapes into the air. I don't know of any relative rate data. Some references we have used concerning stability of VCM in groundwater include the following: Mackay, D.M., Roberts, P.V., Cherry, J.A., Transport of Organic Contaminants in Ground Water. ES&T, 1985, Vol. 19, 384-92; Roberts, P.V., Reinhard, M., Valoceki, A.J., "Movement of Organic Contaminants in Ground Water: Implication For Water Supply," Jour. AWWA, 1982, Vol. 74, 408-13. Various EPA documents concerning VCM. [ VVV 000QG4f>04 18 9. Are You Aware of Any Materials That Could Degrade and Form VCM in the Land Disposal Unit or in the Groundwater? Please Provide Details, Copies of Studies, or References. N.A. -- 1 No -- 12 Yes -- 1 The majority of respondents who had knowledge of materials which could degrade and form VCM in a land disposal unit cited trichloroethylene. Excerpts from individual responses follow. Studies have shown tetrachloroethylene, trichloro ethylene, and dichloroethylene degrade to VCM. See "Anaerobic Transformation, Transport and Removal of Volatile Chlorinated Organics in Groundwater" by Paul R. Wood, Russell F. Lang, and Iris L. Payan of the Drinking Water Research Center, School of Technology, Florida International University, Tamiami Campus, September, 1981. The following degrade to VCM: EDC; 1, 1, 2 trichloroethane; tetrachloroethane. See Attachments B and C to this survey for a listing of recent relevant publications on the subject. Both perchloroethylene and trichloroethylene degrade step wise yielding vinylidene chloride which then degrades to vinyl chloride in a generally well recognized fashion. Almost all land disposal units have all four of these chlorinated materials present, both in the landfill, in the gases from the landfill, and in the leachate from the landfill. The Corvina Landfill in California has received an extensive amount of publicity for this reason. The current literature on these subjects is summarized in Volume I of the Second Edition of the Encyclopedia of PVC. There will be some further information in the future Volume 3 of the Encyclopedia. f VVV 000004i>05 19 Vinyl chloride is a problem in groundwater not from leaching from PVC, but from the microbial degradation (i.e. transformation) of chlorinatd solvents under anaerobic condi tions to vinyl chloride. This topic is being vigorously researched at this time by a number of university programs. For further information, please contact any of the "experts" listed. (1) Vogel, T.M. and McCarty, P.L. "Biotransformation of Tetrachloroethylene to Trichloroethylene, Dichlorethylene, Vinyl Chloride, and Carbon Dioxide Under Methanogenic Condi tions." Applied and Environmental Microbiology, May 1985, p. 1080, Vol. 49, No. 5"I (T) Barrio-Lage, G. , Parsons, F.Z., Nassar, R.S., and Lorenzo, P.A. "Sequential Dehalogenation of Chlorinated Ethenes," Environ. Sci. Technol. Vol. 20, No. 1, 1986, p. 96. (3) Wood, Paul R., Lang, R.F. and Payan, I.L. "Anaerobic Transformation, Transport and Removal of Volatile Chlorinated Organic In Groundwater." Unpublished manuscript, September 1981, Drinking Water Research Center, School of Technology, Florida International University, Tamiami Campers, Miami, Florida 33199. (4) Kobayashi, H. and Rittmann, Bruce E. "Microbial Removal of Hazardous Organic Compounds." Environ. Sci. Technol., Vol. 16, No. 3, 1982, page 170A. F Vw 0004S06 20 10. Describe VCM Concentrations in PVC Monitoring Hells Which May Be Attributed to PVC Casing or Casing Cement. N.A. -- 4 None -- 1 No Information -- 5 No -- 1 None Detected -- 1 Some typical responses were: Believed nil? made no specific determination. We did monitoring (mid 1970's) at a commercial landfill with PVC pipe for wells and concluded results were influenced by the pipe RVCM. I can no longer find the data. Technical articles on this subject have been published in Journal of American Water Works in past 6 years. The work which the National Sanitation Foundation (NSF) has submitted to FDA on RVCM in food-contact PVC, shows that vinyl chloride is not found in water that has been in contact with rigid pipe if the pipe contains less than about 2 ppm of RVCM. The NSF method is sensitive to about 1 ppb. PVC is the standard material of construction for monitoring wells at Superfund sites and for RCRA groundwater monitoring. To my knowledge, there has not been any problem with VCM from the pipe. f vvv 00000^07 21 11. Please Identify Any "Experts" on VCM or Chlorinated Hydro carbons In Groundwater. Names given -- 2 None Known -- 11 Perry L. McCarty Dept, of Civil Engineering Stanford University Stanford, Calif. 94305 Gladys Barrio-Lage Drinking Water Research Center Florida International University Miami, Florida 33199 John T. Wilson Robert S. Kerr USEPA Ada, Oklahoma Environ. Research Lab C. H. Ward and Edward J. Bouwer National Center for Groundwater Research Rice University Houston, Tx. Bruce Rittmann Dept, of Civil Engineering University of Illinois Champaign-Urbana, 111. Joseph M. Suflita Dept, of Botany & Microbiology University of Oklahoma Norman, OK 73019 Lial Tischer. Parsons Group at International University in Miami. r VVV 000004508 22 Kleopfer group which published a recent article in GS&T. Mr. Wil ten Berge, DSM, the Netherlands Mr. J. Prest P. 0. Box 13 The Heath Runcorn (Cheshire) U. K. 00&'0 0^ I 23 12. Please Alert Us of Any Situation Where PVC Compound Waste Is Alleged To Be Causing an Environmental Problem Near a Land Disposal Facility N.A. -- 1 None Known -- 6 No Information -- 2 None for PVC compound waste but numerous instances of vinyl chloride contamination near landfills where chlorinated solvents were disposed and transformed under anaerobic (methanogenic) conditions. See BNA Chemical Regulation Reporter, "Carcinogens: California Officials Probe Conversion of Trichloroethylene into Vinyl Chloride" (Sept. 16, 1983). Another similar instance at a Superfund cleanup site in New Hampshire or Massachusetts. Firestone has such an alleged problem at the Woodlawn County Landfill near the Perryville, Maryland, PVC plant owned by Occidental Chemical. VVV 000004611 f 24 13. Have 7ou Had Any Inquiries From Regulatory Agencies Regarding Landfilling of PVC Wastes and/or VCM Content of These Wastes? No -- 15 N/A -- 1 Yes -- 2 In 1981, state environmental organization requested data on EP Toxicity test for VCM in PVC sludge. Based on inquiries from state officials who administer the RCRA program, tests were performed which showed that for PVC wastes containing less than 500 ppm VCM, leachate from the waste would contain less than 10 ppm VCM and air exposure to VCM for landfill workers would be below OSHA exposure limita tions . Our landfilling was worked out in an understanding with the authorities. This year they have been showing increasing interest in VCM in wastewater. VVV 000004612 f 25 14. Please Send Us Any Additional Information 7ou Have Related to This Subject. N.A. -- 1 None -- 9 Yes -- 1 According to EPA Region III, groundwater from monitor ing wells at Formosa Plastics Corporations PVC plant in Delaware City, Delaware, showed EDC levels up to 3,400 ppb, VCM levels up to 310 ppb and TCE levels of 15-20 ppb. No contami nation in nearby residential water wells was found. EPA is seeking a cleanup agreement with Formosa and the former owner, Stauffer Chemical Co. See, BNA Environmental Reporter, pg. 578 (Aug. 15, 1986). VW 000004613 ! 0Q 0 Attachment B Baier, J. H., and Robbins, S. F., "Vinyl Chloride Contamination of Ground Water, North Bay Shore, New York," Suffolk County Department of Health Services, New York (1983). Baker, L. W., and MacKay, K. P., "Screening models for esti mating toxic air pollution near a hazardous waste landfill." J. Air Pollution Cont. Assn. 35 1190 (1985). Demirjian, Y. A., Westman, T. R., and Rediske, R. R., "The fate of organic pollutants in a wastewater land treatment system using lagoon impoundment and spray irrigation." EPA-600/S2-83077 (Nov. 1983). Department of Environmental Resources Management. "An Investi gation into the Source of Vinyl Chloride Detected at the Preston and Hialeah Water Treatment Plants." Dade County, Florida, (1983). EPA (1979). "Vinyl Chloride Ambient Water Quality Criteria." U.S. Department of Commerce, National Technical Information Service, PB-292 446. Washington, D.C. Gay, B. W., Jr., Noonan, R. C., and Bufalini, J. J., "Oxidation of Ethylene and Halogenated Hydrocarbons at Low Concentratons." Environ. Sci. Technol., 10 58 (1976). Hartmans, S., de Bont, J. A. M., Tramper J., and Luyben, K. Ch. A. M. "Bacterial Degradation of Vinyl Chloride." Bio technology Letters 7 383 (1985). Hill, J. (1976). "Dynamic Behavior of Vinyl Chloride in Aquatic Ecosystems." U.S. Department of Commerce, National Technical Information Service, PB-249 302. Washington, D.C. Kleopfer, R. D., Easley, D. M., Haas, B. B., Jr., Deihl, T. G., Jackson, D. E., and Wurrey, C. J., "Anaerobic Degradation of Trichloroethylene in Soil." Environ. Sci. Technol. 19 277 (1985). Lage-Barrio, G. Parsons, F. Z., Nassar, R. S., and Lorenzo, P. A., "Sequential Dehalogenation of Chlorinated Ethenes." Environ. Sci. Technol. 20 96 (1986) . Lytwynyshyn, G. R., Zimmerman, R. E. Flynn, N. W., Wingender, R., and Olivieri, V., "Landfill Methane Recovery Part II: Gas Characterization." Escor, Inc., Illinois, (1982). wy 000004616 I Attachment B (Cont.) Parsons, F., Wood, P. R., and DeMaraco, J., "Transformations of Tetrachloroethene and Trichloroethene in Microcosms and Groundwater." J. Amer. Wat. Works Assoc. 76 56 (1984). Parsons, F., Lage-Barrio, G., and Rice, Ramona, "Biotransforma tion of Chlorinated Organic Solvents in Static Microcosms." Environ. Toxicol. Chemistry 4 739 (1985). Strier, M. P., "Pollutant Treatability: A Molecular Engineer ing Approach." Environ. Sci. & Technol. 14 28 (1980). Young, P. J., and Parker, A., "The identification and possible environmental impact of trade gases and vapours in landfill gas." Waste Management and Research 1 213 (1983). VVV 000004617 f Attachment C Introductory Study of Biodegradation of Chlorinated Methane, Ethane and Ethene Compounds, June 1980 (6 pages) and June 1981 (15 pages). Anaerobic Transformation, Transport and Removal of Vola tile Chlorinated Organics in Groundwater, Sept. 1981, 41 pages (Removal Section - 17 pages) Behavior and Fate of Hazardous Organic Chemicals in Con taminated Groundwater, Dec. 1982, 72 pages. Occidental Chemical Corporation's Ying to Werner, May 1983, 2 pages: VC in Soil. Occidental Chemical Corporation's Dietz to Werner, June 1983, 2 pages: Evaluation of Chlorocarbon Degradation Reports from Florida International University. BFGoodrich's Gregg to O'Mara, Oct. 1983, 2 pages: Case Study of Groundwater Contamination by Chloroethenes in Florida. Transformation of Tetrachloroethene and Trichloroethene in Microcosms and Groundwater, Feb. 1984, 4 pages. Anaerobic Degradation of Trichloroethylene in Soil, 1985, 4 pages. VVV 000004618 SOURCE: South Coast Air Quality Management District Air Quality Digest, 9150 Flair Drive, El Monte, CA 91731 Dioxins and Furans Placed on Toxics List A class of compounds have been added to the state's list of ambient toxic substances. The Air Resources Board (ARB) identified dioxins and furans, carcinogenic by-products of trash incin eration, as toxic air contaminants. A toxic air contaminant, as defined by the ARB, is an air pollutant "which may cause or contribute to an increase in mortality or an increase in serious illness or which may pose a present or potential hazard to human health." Currently six of the 47 compounds listed in the ARB's identification process have been identified as toxic. They are benzene, hexavelant, chromium, ethy lene dichloride, ethylene dibromide, asbestos, and dioxins. Dioxins and furans were selected for identification as toxic air contaminants because many dioxins have been demonstrated to be carcinogens or have the potential to be carcinogens. Dioxins and furans, most of which nave never been tested carcinogenicity, are emitted into the air from combus tion sources as a mixture. They have frequently been formed as unwanted by-products in the manufacture of chemicals based on chlorinated phe nols, such as some pesticides and wood preservatives, or polychlorinated bi phenyls. None of these materials are manufactured in California, according to a staff report by the ARB, but some are found in pesticides used in the state. Dioxins and furans also are formed when plastics, trash, garbage or wood products are burned. According to ARB's report, it is difficult to quantify or predict with certainty the presence of these substances because they are not a commercially useful product or reagent, and they are produced at such low levels that state of the art technology is required to detect them. "Identification of potential sources is based on limited source test infor mation, hypothetical mechanisms or formation, and circumstantial evidence based on the processes performed at a facility," the report states. The report measures the future impact 10 proposed waste-to-energy plants in Los Angeles County will have on the air. Dioxins and furans would be produeed by these plants, but it has not been determined how much will be produced and to what extent a potential hazard to human health would exist. The ARB and the air quality management districts are mandated to adopt measures to reduce ambient levels of these gases to the lowest level achiev able through use of Best Available Control Technology (BACT). The District's Engineering staff is exploring a Toxic Best Available Control Technology (T-BACT) at pre sent, which, like BACT, would involve a case-by-case review of new stationary sources requiring permits and applying the most efficient control method to reduce emissions. "T-BACT differs from BACT in that cost effectiveness is not as an important priority as reducing the toxic emissions to the extent possible," said Robert Murray, District Senior Engi neering Manager. "If the T-BACT is not feasible, than a dillution and/or sub stitution method may be considered," Murray said. Once the Air Resources Board (ARB) and Department of Health Services (DHS)select a com pound to enter the toxics identi ficationphase, the ARB circulates a request for the relevent info rmation on health effects of the compound from the public. Approximately two months later the A RBformally request DHS to evaluate the available health effects information for the candidate compound and to prepare recommendations re garding effects. As a basis for its recom mendations DHS reviews all availablescientific data associated with the health effects of the compound and makes an assess ment of the health risks posed by exposure to the substance. This evaluation includes a discussion of whether a threshold exposure level exists below which effects do not occur. Simultaneous with prepara tion of the DHS health evalua tion, ARB prepares a compre hensive exposure assessment in cluding information on the com pound's usage, emissions or po tential emissions, persistence in the environment, ambient concen trations and present or potential public exposure. These two seg ments - the exposure assessment and the health effects evaluation --become the risk assessment re port which is the technicalfoun dation for determining if thecompound should be listed as a toxic air contaminant in Califor nia. The ARB makes copies ofthe draft report available for public comment before it is submitted to the Scientific Review Panel(SRP), which reviews the scienti ficproceduresandmethods used, the health and exposure data, and the reports conclusion. The final decision regarding listing of a candidate substances as a toxic air contamination is made by the ARB after a public hearing. Ifthe ARB concurs with thefindings that a compound is a toxic substance and does pose a health risk, the compound is listed by regulation as a toxic air contaminant in the California Administrative Code. Once a compound has been listed as a toxic air contaminant, the control decision or risk management phase of the air toxics program begins. Elfpi Iw AK11 Afe Toxkt Up4M* No. I jr rw 5"? I - <- VVV 00000461 July / August 1986 / Air Quality Digest / Page 15 1ji j Company i !1 TFNNFCO , 2 AIR PROD. 3 CONOCO \n PPG 1 is lire 6 AIR PROD. 7 SHELL LITIGATION UPDATE - VC STANDARD, INDUSTRY VS. GOVERNMENT - AS OF 9/86 Eme RGENC y Releases ii Where Prod'n $ Penalty RV RD MV LBS. VC Misc. Report' i ROL N.l . PVC KY LA LA VC N.l KY LA VC so.non . 24,000 NONE NONE 3n.non 125,000 50,000 17 20 15 10.000 f 1I1-------- 1 i 3 69,000 93,000 YFS 2 Yr. Waiver i LATE LATE LATE 8. CONOCO 9 CONOCO io CONOCO ll GA-PAC. .2 BORDEN 1.3 FIRESTONE :4 OCCIDENTAL OK LA MISS LA PVC MASS PVC LA PVC NJ PVC fOTAI i?s.non 100,000 100,000 625,000 90,000 107,000 490,000 i .qifi.nnn 6 14 10 1 166.000 10,000 27,000 35 55.000 2 2 9,400 21 5,011 Hi 85,000 __ ]_ 9 YFS .24 J 2.00Q+ YES 21 YES 12 77 : WV 000004620 ii1 11. ) i Ij i 1 1 i ! Co m pany -LITIGATION UPDATE VC STANDARD. -INDUSTRY VS. GOVFRNI'WIT 9AS OF CO LU CO < UJ _J LU 0 > s: LU CL Q_ Where Z $ Penalty Od > CD Qd RGENC MV LLI Q U CO --i SI <_J > CO CQ ___I i--1 UD i-H CN i-H CD a l-- ___: Q C_J O ld > > cl CN __i _<_c1 >H 15 ETHYL , "2d O _ _81 182.00Q 16 OCCIDENTAL 17 GOODRICH '118 GOODRICH^ KY aa Ov i--H 9 1 J M .------------------------------------------------1-------------------------- _________ i. 57,000 YES /8 o___i Cd 61 2 Yr. Waiver O' Ll CC > CO LU 5-- d CD c: CD dO > lr dT lr UD cs CD O CO d LTV 3* CD o CO aa <C <_) QL cCaD UdD> cr--n 20 BORDEN 21 BORDEN 22 DOW 23 DOW X h-- <__C1 LA CD D=- CDD> <C 25 PPG 26 UCC VC TX aaaa =a CN 1 --i r-n =r CN CDI CD X cr, c CD O 1-- CD CD CD LO i--t 23,000 ... 1 YES L 2H. 003 . 32.COO CO CO CO cr. LL Ll Ll Ll >- >- a: CO o ScdI CD LU cr CN -- O ---- VVV 000004621 ---- --