SOLVENTS STUDY ** CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION ** U.S. Environmental Protection Agency Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009) Hazardous Waste Identification Division (5304W) Washington, DC 20460 Table of Contents 1.0 Study Background 1.1 Legislative and Judicial Background 1.1.1 Existing Solvent Listings and the Regulatory Definition of Solvent 1.1.2 Summary of EDF Settlement Agreement 1.2 Industry Identification Process 1.2.1 Research to Identify Potential Uses of Solvents 1.2.2 Development of RCRA 3007 Preliminary Questionnaire Mailing List 2.0 Representativeness of RCRA 3007 Questionnaire Data to National Data 2.1 Solvents Industry Study Methodology 2.2 Confidence Level of Solvents Industry Study Results 3.0 Data Management and Waste Management Practices 3.1 Data Management and Analyses 3.2 Identification of Current Waste Management Practices 4.0 Discussion of Solvents Study Chemicals 4.1 Allyl Chloride 4.1.1 Wastes From Use as a Solvent 4.1.2 Management Practices 4.1.3 Health Data 4.2 Aniline 4.2.1 Wastes From Use as a Solvent 4.2.2 Management Practices 4.2.3 Health Data 4.3 Diethylamine 4.3.1 Wastes From Use as a Solvent 4.3.2 Management Practices 4.3.3 Health Data 4.4 1.4-Dioxane 4.4.1 Wastes From Use as a Solvent 4.4.2 Management Practices 4.4.3 Health Data 4.5 Ethylene Oxide 4.5.1 Wastes From Use as a Solvent 4.5.2 Management Practices 4.5.3 Health Data 4.6 Bromoform 4.6.1 Use as a Solvent 4.6.2 Health Data 4.7 Vinylidine Chloride 4.7.1 Use as a Solvent 4.7.2 Health Data List of Figures Figure 1-1 RCRA 3007 Questionnaire Mailing List, by State List of Tables Table 1-1 Potential Allyl Chloride Users Identified from Chemical Abstracts Table 1-2 Potential Aniline Users Identified from Chemical Abstracts Table 1-3 Potential Bromoform Users Identified from Chemical Abstracts Table 1-4 Potential Diethylamine Identified from Chemical Abstracts Table 1-5 Potential 1,4-Dioxane Users Identified from Chemical Abstracts Table 1-6 Potential Ethylene Oxide Users Identified from Chemical Abstracts Table 1-7 Potential Vinylidene Chloride Users Identified from Chemical Abstracts Table 1-8 Total Reporters and Potential Solvent Use, by Chemical Table 1-9 Number of Facilities Falling Within Potential Solvent Use Quantities Ranges Table 2-1 Cross-Reference of TRI Chemicals with Seven Chemicals of Concern Table 2-2 Total Reporters and Use by Solvent Table 2-3 Solvent Production, Solvent Use, and Survey Results Table 2-4 Solvent Specific Confidence Rationales Table 3-1 Specific Gravities of Solvents Table 4-1 Facilities Using Allyl Chloride in 1993 and Industrial Sector Table 4-2 Use of Allyl Chloride By Industry Table 4-3 Quantity of Allyl Chloride Waste Generated for Each Type Generated Table 4-4 Generation Statistics for Allyl Chloride Table 4-5 Facilities Using Aniline in 193 and Industrial Sector Table 4-6 Use of Aniline By Industry Table 4-7 Quantity of Aniline Waste Generated for Each Type Generated Table 4-8 Generation Statistics for Aniline Table 4-9 Facilities Using Diethylamine in 1993 and Industrial Sector Table 4-10 Use of Diethylamine By Industry Table 4-11 Quantity of Diethylamine Waste Generated for Each Type Generated Table 4-12 Generation Statistics for Diethylamine Table 4-12 Facilities Using 1,4-Dioxane in 1993 and Industrial Sector Table 4-13 Use of 1,4-Dioxane By Industry Table 4-14 Quantity of 1,4-Dioxane Residuals Table 4-15 Generation Statistics for 1,4-Dioxane Table 4-16 Facilities Using Ethylene Oxide in 1993 and Industrial Sector Table 4-17 Use of Ethylene Oxide By Industry Table 4-18 Quantity of Ethylene Oxide Waste Generated for Each Type Generated Table 4-19 Generation Statistics for Ethylene Oxide Appendices Appendix A: Final Memorandum on the Chemical Abstract Search Appendix B: Instructions from the Toxic Release Inventory Reporting Form R and Instructions Appendix C: List of industries and chemicals these industries use, by SIC Code. Appendix D: List of rationale for removing industries from further study as solvent users. Appendix E: RCRA 3007 Preliminary Survey of Solvent Use Appendix F: Preliminary Questionnaire Mailing List of 1,497 Facilities. Appendix G: Preliminary Questionnaire Data for All Responders By SIC Code Appendix H: RCRA 3007 Survey of Solvent Use Appendix I: Tables of Waste Generation, Characterization, and Management, by Solvent 1.0 Study Background 1.1 Legislative and Judicial Background 1.1.1 Existing Solvent Listings and the Regulatory Definition of Solvent As part of the Hazardous and Solid Waste Amendments (HSWA) of 1984, EPA was required to make determinations as to whether certain wastes are hazardous under RCRA. Among these are solvent wastes. Five hazardous waste listings for solvent wastes have been promulgated to date at 40 CFR §261.31(a). These are shown below, and the basis for listing these solvents, toxicity (T) or ignitability (I) is shown in parentheses after the listing description. F001: The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. (T) F002: The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. (T) F003: The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. (I) F004: The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. (T) F005: The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures. (I,T) The existing solvent listings in 40 CFR 261.31 apply to spent solvents that are used for their "solvent properties," as defined in the December 31, 1985 Federal Register (50 FR 53316). This definition of "solvent use" was included in the RCRA §3007 Solvent Use Questionnaire used to obtain information to support the solvent investigation: "Solvents are used for their "solvent" properties -- to solubilize (dissolve) or mobilize other constituents. Examples of such solvent use include degreasing, cleaning, and fabric scouring, use as diluents, extractants, and reaction and synthesis media, and for other similar uses. This definition is discussed in the listing determination for F001-F005 solvents, 50 FR 53316, December 31, 1985. A chemical is not used as a solvent if it is used only for purposes other than those described above. 1.1.2 Summary of EDF Settlement Agreement The Environmental Defense Fund (EDF) and EPA entered into a consent decree to resolve most of the issues raised in a civil action undertaken by the Environmental Defense Fund (EDF v. Browner, Civ. No. 89-0598 (D.D.C.)), in which the Agency agreed, among other things, to a schedule for making a listing determination and a study on spent solvents. The consent decree was approved by the court on December 9, 1994. As modified, the consent decree provides that the listing determination is scheduled to be proposed for public comment on or before July 31, 1996 and promulgated on or before May 31, 1997. This listing determination includes the use following spent solvents, still bottoms from the recovery of the following solvents, and spent solvent mixtures thereof: cumene, phenol, isophorone, acetonitrile, furfural, epichlorohydrin, methyl chloride, ethylene dibromide, benzyl chloride, p-dichlorobenzene, 2-methoxyethanol, 2-methoxyethanol acetate, 2-ethoxyethanol acetate, and cyclohexanol. For an additional set of solvents, EPA agreed to conduct a study, in lieu of a listing determination, and issue a final report. The study is scheduled to be issued by August 30, 1996. This study is to discuss the wastes associated with the use of the materials as solvents, the toxicity of the wastes, and a description of the management practices for the wastes. These additional chemicals are: diethylamine, aniline, ethylene oxide, allyl chloride, 1,4-dioxane, 1,1-dichloroethylene, and bromoform. 1.2 Industry Identification Process The solvents investigation undertaken to support this study covered spent solvents, still bottoms from the recovery of spent solvents, and mixtures of spent solvents. Spent solvents are solvents that have been used and are no longer fit for use without being regenerated, reclaimed, or otherwise processed (50 FR 53316, December 31, 1985). The Agency also investigated the residuals generated by processes that use the solvents of interest. Residuals include spent solvents, residuals generated during solvent recovery, and any residuals generated after the solvent has been introduced into the process that might include some concentration of spent solvent. The solvents under investigation included the seven chemicals for which EPA must make a listing determination as well as the seven solvent study chemicals that are the subject of this report. EPA's solvents investigation did not consider processes where the constituents of interest are used as raw materials or principally sold as commercial products (i.e., where the constituent is not used for its solvent properties). This approach is similar to discussions in the December 31, 1985 Federal Register notice for existing listings, which noted that "...process wastes where solvents were used as reactants or ingredients in the formulation of commercial chemical products are not covered by the listing." Examples of the use of solvents as reactants or ingredients are the use of solvents in the manufacture of paints and coatings. It is important to note, however, that solvents added as a thinner to product paints and coatings after purchase are being used for their solvent properties and, after use, will meet any applicable spent solvent listings. 1.2.1 Research to Identify Potential Uses of Solvents As stated above, the solvents investigation is unique in that it focuses on facilities using chemicals for their solvent properties. Unlike a traditional industry investigation, which would focus on a specific waste generated in a process unique to one industry, the solvents investigation focussed on the activities of all users of these solvents. The immediate challenge to the program was the identification of industries using the chemicals as solvents. To address this challenge, significant background research was conducted on each chemical to determine its probable solvent uses. Literature searches were conducted to identify industries using the chemicals as solvents. Initial sources searched included Chemical Engineering Handbook, the Industrial Solvents Handbook, and the SRI Chemical Economics Handbook to obtain basic information on production and potential solvent uses. Chemical Abstracts were searched for a four- to twelve-year period for abstracts on potential uses of each of the seven chemicals as a solvent. The number of years searched depended on the number of references available on a specific chemical. Each abstract was reviewed a team of chemists and chemical engineers to determine whether the use constituted a potential solvent use (as defined by EPA/OSW) and to relate the use to industries that may employ the solvent in their processes. Chemical Abstracts provided background on specific solvent uses and were used to determine potential users by Standard Industrial Classification (SIC) code. These efforts produced a list of SIC codes for industries suspected of using the chemicals for their solvent properties. The final memorandum on the Chemical Abstract search is included in Appendix A. The results of the search are summarized in Tables 1-1 through 1-7. Where SIC codes are followed by a question mark (e.g., 2833? for diethylamine use), the potential use of the chemical by facilities in these SIC codes is highly questionable based on the Chemical Abstracts. They are included for completeness. The Toxic Release Inventory (TRI) database was searched for addresses of facilities reporting releases of the 7 chemicals. The TRI initially was used to develop a baseline of SIC codes for solvents that were reported "as otherwise used". This use classification most paralleled EPA's definition of solvent use. However, some limitations apply. The TRI did not provide complete coverage of the affected industries for a number of reasons. Not all of the 7 solvents under investigation are included in the TRI reporting list; diethylamine is not on the list of TRI chemicals. The TRI has a reporting threshold of 10,000 pounds. Facilities using less than that quantity are not required to complete TRI reports (i.e., are not included in the TRI database) and, therefore, would not have been identified as potentially subject to the solvents listing determination. Finally, the TRI is limited to facilities in SIC Codes 20-39, which encompass manufacturing industries. Appendix B to this report contains the instructions from the Toxic Release Inventory Reporting Form R and Instructions booklet. Given the TRI limitations, Chemical Abstract SIC codes were cross-referenced with the TRI SIC codes to develop a final SIC Code list. TRI does not specify that a chemical is used as a solvent, rather, it notes "as otherwise used" (i.e., as a chemical processing aid, as manufacturing aid, or ancillary or other use). Where a chemical was reported to the TRI by facilities in a SIC Code group as otherwise used, but did not correspond to any suspected or known solvent use from Chemical Abstracts research, the SIC Code was dropped. For example, the TRI indicated that the Leather Tanning and Finishing Industry (SIC Code 3111) potentially utilized phenol, 2-methoxyethanol, and acetonitrile as solvents. Chemical literature searches indicated that these chemicals were part of formulations and, therefore, did not meet the solvent definition. Subsequently, SIC Code 3111 was dropped from further study. Appendix C to this report presents two lists of industries and chemicals these industries use, by SIC Code. The first list is SIC Codes potentially affected by the listing determination/study and the second is SIC Codes removed from further study. Appendix D presents two lists, the first relating industries to solvent uses identified and the second detailing the rationale for removing industries from further study as solvent users. By identifying the potential solvent uses of each chemical, it was possible to link uses to specific industries. Once industries were identified, a final facility address list could be developed. The TRI was the primary source of facility information for the solvents pre-questionnaire mailing list. In order to ensure the broadest and most complete list of potentially affected facilities, additional data sources were consulted. These sources include: o Trade associations, such as the Pharmaceutical Research and Manufacturers of America, provided their membership list. EPA also conducted discussions with trade groups representing potentially affected industries such as the Chemical Manufacturers Association, the Semiconductor Manufacturers Association, the Chemical Distributor's Association, and the Synthetic Organic Chemical Manufacturers Association. o The databases supporting EPA's development of two effluent guidelines were searched for facility addresses. The effluent guideline databases searched included Pharmaceuticals I and II, and the Organic Chemicals, Plastics, and Synthetic Fibers. o The National Air Toxics Inventory of Chemical Hazards (NATICH) was accessed for facility addresses. o The address list developed for the RCRA 3007 Questionnaires for petroleum refinery facilities was used. o Addresses for pulp and paper mills developed during a study of Subtitle D disposal of pulp and paper mill sludge was used. o Addresses for users of solvents were obtained from the Toxic Substances Control Act (TSCA) Office of Pollution Prevention and Toxics (OPPT) at EPA. These addresses resulted from OPPT's evaluation of solvents under the Source Reduction Review Project (SRRP). o Addresses were obtained from Dun and Bradstreet (an industrial address book) or the Thomas Register (a listing of product manufacturers). Industries covered by these sources included rubber manufacture; paper and paperboard products; printing; selected food-related industries; cement, concrete, and gypsum manufacture; iron, steel, copper, and aluminum manufacture; electronics and semiconductors; and medical supply manufacture. o Finally, facilities that received a RCRA 3007 Chlorinated Aliphatics questionnaire were deleted from the mailing list because solvents questions were included in the questionnaire mailed to that industry. 1.2.2 Development of RCRA 3007 Preliminary Questionnaire Mailing List From these data gathering activities, 1,497 facilities potentially subject to listing determinations were identified. A copy of the preliminary questionnaire is included in Appendix E to this report. The list of facilities is included in Appendix F to this report. EPA did not include laboratories in the preliminary questionnaire mailing. The Agency attempted to obtain laboratory client lists and the identity of firms purchasing aggregate volumes of solvents from the National Association of Chemical Distributors members; however, such data were not made available. EPA also worked with the American Chemical Society (ACS) and their laboratory network to define the universe of affected laboratories. The Agency presented information on the solvents listing determination and initiated a dialogue with the ACS Task Force on RCRA and Laboratories at their meeting on May 14, 1994 in Washington, D.C. Similar information was presented at the Twelfth Annual College and University Hazardous Waste Conference on August 8, 1994. Based on these discussions, it is believed that nearly all laboratories dispose of the solvents under investigation as waste rather than recovering them. Further, anecdotal information indicates that the solvents are managed as hazardous, many because they exhibit the characteristic of ignitability. Discussions with ACS and the colleges and universities provided a clearer picture of waste management at universities and further anecdotal information on management of the solvents under investigation. Of the 1,497 preliminary questionnaires mailed, less than 600 responded that one or more of the solvents were used at that facility. Further investigations (primarily through telephone calls to verify data) eliminated additional facilities. The definition of "solvent" appeared to be unclear to some respondents, who provided solvents quantities when in fact the compound was part of a formulation or was not used for its solvent properties. For example, 1,4-dioxane is used as a stabilizer in 1,1,1-trichloroethane which is already regulated as hazardous waste codes F001 and F002 when used as a solvent. Many facilities reported 1,4-dioxane use; however, as an additive it is not used for its solvent properties and does not meet the regulatory definition of solvent provided in Section 1.1.1. Hence, data would reflect use of 1,4-dioxane as an additive rather than a solvent, and any residuals generated would already be regulated as RCRA hazardous waste. In addition, a number of facilities did not check the list of solvents carefully and reported volumes for incorrect compounds, such as those who reported diethylamine use when diethanolamine was used. Table 1-8 presents data from the RCRA 3007 Preliminary Solvents Use Questionnaire on potential solvent use in 1992. However, these data include uses reported that subsequently were removed from consideration (e.g., uses reported by TSDs). The use is considered "potential" because there is no means to determine with complete certainty that the use reported is truly use as a solvent. To the extent possible, this table reflects totals as revised to eliminate the errors discussed above. Totals shown as greater than (>) or less than (<) reflect totals that do not include confidential business information. Appendix G presents detailed non-CBI data for all responders by SIC code. The facilities making claims of confidential business information (CBI) on their use have been deleted from this list. The data collected from the Preliminary Solvents Use Questionnaire were limited to the total volume of solvents used in 1991 and 1992. From the information obtained from the preliminary questionnaire, EPA proceeded to develop a detailed solvent use survey to collect process, waste generation, and waste management information, which was under the authority of RCRA Section 3007. Trade associations also were given the opportunity by EPA to review the draft questionnaire for technical accuracy and relevance. The RCRA 3007 Questionnaire for Solvents Use was based on a new questionnaire design. In addition to traditional questions regarding generation of residuals, residual characterization, and waste management practices, the new format of the questionnaire enabled EPA to collect information on solvent recovery, comanagement of solvents in recycling units, and waste minimization. In addition, respondents were asked to identify all other on-site and captive off-site units in which solvent residuals are managed, the common name and type of unit, the unit's location (on or captive off site), the residual and quantity managed in 1992, other wastes comanaged in the unit, and the permit status of the unit. Finally, facilities are asked to report shipments to off-site facilities and treatment used (if known). The questionnaire was designed to enable EPA to gain a clearer understanding of the residuals generated from the use of the seven chemicals under investigation, their characterization and management, and the management of solvent residuals in specific units. After approval from all participating Agency parties, the draft Solvents Use Questionnaire was field tested in seven facilities in Pennsylvania, New Jersey, and Texas. The final Solvents Use Questionnaire was revised in response to comments received during field testing and was then mailed to selected positive responders to the preliminary questionnaire. A copy of the Questionnaire is included in Appendix H to this report. Of the corrected positive responses to the preliminary questionnaire, a number included small users (e.g., 5 mL per year, 1 gallon per year). Because of the complexity of the full RCRA §3007 Solvent Use Questionnaire, an effort was made to eliminate these very small users of solvents from the mailing list for the Questionnaire. EPA examined the volume of solvents reported and determined that facilities reporting the use of less than 1,200 kilograms per year combined of all seven solvents under investigation could be eliminated from further study. This cutoff corresponds to a monthly use of 100 kilograms or less of the seven solvents under investigation. Table 1-9 presents the breakdown of the number of facilities reporting greater than or equal to 1,200 kilograms per year of all seven chemicals, by solvent. For reference, Table 1-9 also presents the number of facilities reporting use of less than 120 kilograms per year and 120 to less than 1,200 kilograms of an individual solvent. In all, 157 facilities were sent a Questionnaire. The list of facilities is presented in Figure 1-1. The impact of limiting the study population and its potential impact on the estimation of national solvent residual generation rates is discussed in Section 2.0 of this report. Figure 1-1 RCRA 3007 Questionnaire Mailing List, by State FACILITY NAME, CITY , STATE M & M CHEMICAL EQUIPMENT CO.,ATTALLA,AL DU PONT MOBILE PLANT,AXIS,AL CIBA-GEIGY CORP. MCINTOSH SITE,MC INTOSH,AL INTEL CORP. - MAIN CHANDLER CAMPUS,CHANDLER,AZ CONTINENTAL CIRCUITS CORP.,PHOENIX,AZ OIL AND SOLVENT PROCESS CHEMISTRY,AZUSA,CA CHIRON CORPORATION,EMERYVILLE,CA ADVANCED DIELECTRICS INC.,FREMONT,CA PCA METAL FINISHING INC.,FULLERTON,CA CHEVRON CHEMICAL CO.,RICHMOND,CA CHEVRON USA INC. - RICHMOND REFINERY,RICHMOND,CA UNOCAL SAN FRANCISCO REFINERY,RODEO,CA NEC ELECTRONICS INC., ROSEVILLE FACILITY,ROSEVILLE,CA HEWLETT-PACKARD CO.,SAN JOSE,CA VLSI TECHNOLOGY INC.,SAN JOSE,CA GENENTECH, INC.,SOUTH SAN FRANCISCO,CA AMGEN, INC.,THOUSAND OAKS,CA BACHEM INC.,TORRANCE,CA NCR CORPORATION,COLORADO SPRINGS,CO HEWLETT-PACKARD CO.,FORT COLLINS,CO NCR MICROELECTRONICS,FORT COLLINS,CO BOEHRINGER INGELHEIM PHARMACEUTICALS, INC.,RIDGEFIELD,CT SEAFORD FIBERS PLANT,SEAFORD,DE ZENECA - FAIRFAX SITE,WILMINGTON,DE PCR INC.,GAINESVILLE,FL AT&T MICROELECTRONICS-ORLANDO PLANT,ORLANDO,FL CONTINENTAL CIRCUITS INC.,WINTER SPRINGS,FL NORTHERN ENGRAVING CORP.,LANSING,IA ABBOTT LABORATORIES,ABBOTT PARK,IL ARMOUR PHARMACEUTICAL COMPANY,BRADLEY,IL ARMSTRONG CONTAINERS INC. METAL DECORATING DIV.,FRANKLIN PARK,IL BF GOODRICH CO - HENRY PLANT,HENRY,IL ABBOTT LABORATORIES,NORTH CHICAGO,IL PFANSTIEHL LABORATORIES,WAUKEGAN,IL ELI LILLY & CO.,CLINTON,IN RHONE-POULENC INC.,HAMMOND,IN ELI LILLY & CO.,INDIANAPOLIS,IN ELI LILLY & CO.,INDIANAPOLIS,IN ELI LILLY & CO. - MC RESEARCH,INDIANAPOLIS,IN C.P. RECYCLING,LOGANSPORT,IN GMC, NAO TRUCK FORT WAYNE ASSEMBLY,ROANOKE,IN ELI LILLY & CO.,SHADELAND,IN INDUSTRIAL FUELS & RESOURCES, INC.,SOUTH BEND,IN ASHLAND OIL COMPANY CATLETTSBURG REFINERY,CATLETTSBURG,KY COMMONWEALTH ALUMINUM CORP.,LEWISPORT,KY EXXON CHEMICAL AMERICAS-BATON ROUGE CHEMICAL PLANT,BATON ROUGE,LA UNIROYAL CHEMICAL CO. INC.,GEISMAR,LA CITGO PETROLEUM CORP. - LAKE CHARLES COMPLEX,LAKE CHARLES,LA CIBA-GEIGY CORP. - ST GABRIEL PLANT,SAINT GABRIEL,LA CWM, INC - LAKE CHARLES FACILITY,SULPHUR,LA Figure 1-1 RCRA 3007 Questionnaire Mailing List, by State (continued) FACILITY NAME, CITY , STATE ANITEC PRINTING PLATE,HOLYOKE,MA ANITEC PRINTING PLATE,HOLYOKE,MA SHIPLEY CO. INC.,MARLBOROUGH,MA AT&T - MERRIMACK VALLEY WORKS,NORTH ANDOVER,MA POLAROID CORP. - NORWOOD FACILITY,NORWOOD,MA STAHL USA,PEABODY,MA POLAROID CORP.,WALTHAM,MA ANALOG DEVICES,WILMINGTON,MA KANASCO LTD.,BALTIMORE,MD TOTAL PETROLEUM INC.,ALMA,MI NORTRU. INC.,DETROIT,MI PARKE-DAVIS,HOLLAND,MI UPJOHN COMPANY,KALAMAZOO,MI PONTIAC WEST ASSEMBLY,PONTIAC,MI GMC, TECHNICAL CENTER,WARREN,MI WARREN TRUCK ASSEMBLY PLANT,WARREN,MI ZEELAND CHEMICAL PRODUCTS,ZEELAND,MI 3M HUTCHINSON AVTD AND TMD PLANTS,HUTCHINSON,MN IBM CORP. - ROCHESTER,ROCHESTER,MN 3M CENTER,SAINT PAUL,MN CEMTECH (SELMA PLANT),FESTUS,MO SIGMA CHEMICAL CO.,SAINT LOUIS,MO MALLINCKRODT SPECIALTY CHEMICALS CO. - ST LOUIS,ST. LOUIS,MO PACKAGE PRODUCTS SPECIALTY,CHARLOTTE,NC DU PONT - FAYETTEVILLE WORKS,FAYETTEVILLE,NC BURROUGHS WELLCOME CO.,GREENVILLE,NC GLAXO INC.,RESEARCH TRIANGLE PARK,NC HADCO CORP.,DERRY,NH POLYCLAD LAMINATES INC.,FRANKLIN,NH HOECHST CELANESE CORP.,BRANCHBURG TOWNSHIP,NJ CARTER-WALLACE, INC.,CRANBURY,NJ SCIENTIFIC DESIGN CO. INC.,LITTLE FERRY,NJ NAPP CHEMICALS INC.,LODI,NJ E. R. SQUIBB & SONS,NORTH BRUNSWICK,NJ HOFFMANN-LA ROCHE INC.,NUTLEY,NJ MOBIL OIL PAULSBORO REFINERY,PAULSBORO,NJ SUVAR CORP.,PENNSAUKEN,NJ BRISTOL-MYERS SQUIBB PHARMACEUTICAL GP,PRINCETON,NJ MERCK & CO. INC. - RAHWAY SITE,RAHWAY,NJ CIBA-GEIGY CORP., PHARMACEUTICALS DIV.,SUMMIT,NJ AMP-AKZO CORP.,AQUEBOGUE,NY PFIZER, INC.,BROOKLYN,NY IBM CORP.-ENDICOTT FACILITY,ENDICOTT,NY IBM CORP. - EAST FISHKILL FACILITY,HOPEWELL JUNCTION,NY AZON CORP.,JOHNSON CITY,NY HADCO CORPORATION - OWEGO DIVISION,OWEGO,NY LEDERLE LABORATORIES DIVISION,PEARL RIVER,NY STERLING ORGANICS,RENSSELAER,NY Figure 1-1 RCRA 3007 Questionnaire Mailing List, by State (continued) FACILITY NAME, CITY , STATE KODAK PARK SITE,ROCHESTER,NY AYERST LABORATORIES INC.,ROUSES POINT,NY GE PLASTICS, SELKIRK OPERATION,SELKIRK,NY BRISTOL-MYERS SQUIBB CO.,SYRACUSE,NY JOSEPH C. WILSON CENTER FOR TECHNOLOGY, XEROX CORP,WEBSTER,NY HUKILL CHEMICAL CORPORATION,BEDFORD,OH CHRYSLER MOTORS TOLEDO ASSEMBLY,TOLEDO,OH CWM RESOURCE RECOVERY, INC.,WEST CARROLLTON,OH SUN REFINING & MARKETING CO.,TULSA,OK INTEL CORP.,ALOHA,OR PRAEGITZER INDUSTRIES INC.,DALLAS,OR FUJITSU MICROELECTRONICS INC., GRESHAM MANUF. DIV.,GRESHAM,OR AT&T MICROELECTRONICS - ALLENTOWN,ALLENTOWN,PA LONZA INC.,CONSHOHOCKEN,PA HARRIS SEMICONDUCTOR,MOUNTAINTOP,PA MERCK & CO. INC.,RIVERSIDE,PA CEMTECH,WAMPUM,PA WYETH-AYERST LABORATORIES INC.,WEST CHESTER,PA BAXTER HEALTHCARE CORP. OF PR,ANASCO,PR STERLING PHARMACEUTICALS INC.,BARCELONETA,PR UPJOHN MANUFACTURING COMPANY,BARCELONETA,PR SMITHKLINE BEECHAM PHARMACEUTICALS CO.,CIDRA,PR SCHERING PLOUGH PRODUCTS,MANATI,PR ELI LILLY INDUSTRIES INC.,MAYAGUEZ,PR OCG MICROELECTRONIC MATERIALS,EAST PROVIDENCE,RI ARKWRIGHT INC.,FISKEVILLE,RI MOBAY CORP., BUSHY PARK,GOOSE CREEK,SC FUJI PHOTO FILM INC.,GREENWOOD,SC DU PONT,CHATTANOOGA,TN TENNESSEE EASTMAN DIVISION,KINGSPORT,TN GREAT LAKES CHEMICAL CORP.,NEWPORT,TN AMOCO CHEMICAL CO. - CHOCOLATE BAYOU PLANT,ALVIN,TX ARGON MEDICAL,ATHENS,TX ADVANCED MICRO DEVICES INC.,AUSTIN,TX IBM,AUSTIN,TX EXXON,BAYTOWN,TX EXXON CHEMICAL AMERICAS - BAYTOWN CHEMICAL PLANT,BAYTOWN,TX MOBIL BEAUMONT REFINERY,BEAUMONT,TX PHILLIPS 66 CO.,BORGER,TX SGS-THOMSON MICROELECTRONICS,CARROLLTON,TX LYONDELL PETROCHEMICAL CO.- CHANNELVIEW COMPLEX,CHANNELVIEW,TX GOODYEAR TIRE & RUBBER CO. - BEAUMONT CHEM PLANT,CHEEK,TX OXY CHEM CORPUS CHRISTI PETROCHEMICALS,CORPUS CHRISTI,TX TEXAS INSTRUMENTS INC. - EXPRESSWAY SITE,DALLAS,TX ALCON LABORATORIES, INC.,FORT WORTH,TX Figure 1-1 RCRA 3007 Questionnaire Mailing List, by State (continued) HITACHI SEMICONDUCTOR AMERICA,IRVING,TX VLSI TECHNOLOGY INC.,SAN ANTONIO,TX GIBRALTAR CHEMICAL RESOURCES INC.,TYLER,TX NATIONAL SEMICONDUCTOR CORP.,WEST JORDAN,UT DU PONT,MARTINSVILLE,VA IBM ESSEX JUNCTION VERMONT,ESSEX JUNCTION,VT BOEING COMMERCIAL AIRPLANE GRP,EVERETT,WA IMMUNEX CORPORATION,SEATTLE,WA POPE & TALBOT WIS INC.,EAU CLAIRE,WI NORTHERN ENGRAVING CORP., HOLMEN DIV,HOLMEN,WI SHELL CHEMICAL CO., POINT PLEASANT POLYESTER PLANT,APPLE GROVE,WV RHONE-POULENC AG CO. - INSTITUTE PLANT,CHARLESTON,WV 2.0 Representativeness of RCRA 3007 Questionnaire Data to National Data This section describes the preliminary conclusions reached about the coverage of facilities achieved during the solvents industry study for potential listing determinations for residuals generated by the use of the seven chemicals. EPA is confident that it identified and surveyed all of the large users of these chemicals as solvents and high-end generators of solvent residuals. Most of the seven chemicals are used as solvents for very specific uses by specific industries. Further, most of the seven chemicals included on the lists of chemicals reported in the Toxic Release Inventory. Thus, as discussed below, EPA is confident that large users were identified. EPA did not pursue an industry study methodology based on random sampling; rather, EPA made a significant effort to identify users of these chemicals as solvents and collect data directly from facilities at which there was a reason for suspected solvent use for at least one of the seven chemicals under study. With the probable exception of 1,4-dioxane, solvent uses of these chemicals of concern are relatively obscure when compared to solvent uses of many F001 - F005 solvents (e.g., methylene chloride and 1,1,1-trichloroethylene). Therefore, it was possible to identify and survey all facilities that might reasonably be expected to use significant quantities (i.e., greater than 1,200 kg per year) of these chemicals as solvents. This industry study does not claim to have identified all facilities that used these seven chemicals as solvents. However, for most of the seven chemicals of concern, industry study conclusions about the extent of solvent use were confirmed by taking national production and import/export totals for each of the seven chemicals and subtracting out: 1)identified nonsolvent uses of these chemicals (identified from other sources such as SRI), and 2)total solvent use quantities as identified in RCRA §3007 questionnaire. For most of the seven chemicals of concern, the industry study concluded that solvent usage is either negligible or limited to a extremely narrow uses by a small number of facilities. The exception to this conclusion is 1,4-dioxane, which is widely used in laboratories. The specific industry study conclusions about issues relating to identification of solvent users and support for those conclusions are discussed below. 2.1 Solvents Industry Study Methodology Step One:Identification of Industries and Processes Using these Chemicals as Solvents As described in Section 1.2.1, an extensive literature was undertaken to identify potential uses and users of the seven chemicals as a solvent as defined by EPA. The primary reference source for this literature search was Chemical Abstracts, which is discussed below. Chemical uses identified from Chemical Abstracts may be limited by the following considerations: (1) solvents uses by many industries may be considered "confidential" and, therefore, not published; (2) solvent use abstracts may not have been identified in the years surveyed, previous years' abstracts may have identified additional uses; (3) abstracts were sometimes ambiguous as to the nature of the activity for the chemical listed (although a conservative approach was taken where ambiguity existed); and (4) solvents used in a particular study may not have been identified in the abstract and, therefore, solvent use went undetected. Although use of Chemical Abstracts to identify uses of the solvents being investigated has its drawbacks, no better supplementary source for solvent use identification exists. Even with the limitations inherent in Chemical Abstracts, few, if any, solvent uses for the study chemicals were missed using this extensive literature search. Step Two:Cross-Referencing of "Target" SIC Code List With Other Data Sources to Identify Specific Facilities Once the list of SIC codes was developed, several searches were performed to identify specific facilities in those industries that might use one of the chemicals under study. The methodology used to identify specific facilities that might use any of the seven chemicals as solvents is described in Section 1.2.1. Table 2-1 presents a cross-reference of chemicals reported in TRI (the primary source for facility addresses) and the seven chemicals of concern. The Agency also conducted meetings with members of the National Association of Chemical Recyclers, however, their membership was not surveyed directly. Rather, some recyclers were identified through other sources, primarily TRI. Compilation of RCRA 3007 Preliminary Questionnaire Data In all, a total of 1,497 preliminary questionnaires were distributed to facilities across the country using the methodology described above. These preliminary questionnaires requested information on solvent use quantities only (not solvent residual generation or management, and facilities were not requested to characterize the solvent use). Responses to the preliminary questionnaire show that some specific chemicals are used as solvents for a very limited number of industries in very small quantities while a few chemicals are used in relatively larger quantities across numerous industries. Of the 1,497 preliminary questionnaires mailed, less than 273 reported any solvent use of one or more of the seven chemicals. Follow-up phone calls were made to facilities that reported solvent use for several low-volume solvent use chemicals (e.g., vinylidene chloride, bromoform) and data corrections were made in the preliminary questionnaire data set. Information gathered during these follow-up calls revealed that many facilities over-reported solvent use either from 1) a misapplication of the EPA definition of solvent use, 2) general ignorance of the precise use of the chemical at the facility and therefore a report of total amount purchased or used at the facility, or 3) mistaken reading of the chemicals queried (e.g., diethanolamine mistaken for diethylamine). It should be noted, however, that follow-up calls were not made to many facilities that reported solvent use of larger-volume solvents (e.g., 1,4-dioxane). Therefore, based on the results of follow-up phone calls that were made, it can be assumed that preliminary questionnaire use data do overestimate solvent use for a portion of the 1,497 facilities surveyed. Following tabulation of preliminary questionnaire data, all facilities that reported greater than 1,200 kg of solvent use in the preliminary questionnaire for 1992 (157 facilities) were sent "full" RCRA 3007 questionnaires to obtain detailed information on solvent use, solvent residual generation, and management. Thus, all large-quantity solvent users were captured and were sent a full RCRA §3007 questionnaire if the facility was sent a preliminary questionnaire. 2.2 Confidence Level of Solvents Industry Study Results EPA focused its efforts during this industry study on identifying the large quantity users of the seven chemicals as solvents and potential large quantity generators of these spent solvent wastes (if listed) using the industry study methodology described above. EPA is confident that the industry study identified and characterized all large quantity solvent users. In some cases, significant changes in the reported use of a solvent between the 1992 Preliminary Questionnaire and the 1993 Questionnaire can be seen. Overall, the preliminary questionnaire totals included amounts reported by commercial treatment, storage, and disposal (TSD) facilities. In some cases, such as bromoform and vinylidene chloride, management by a TSD accounts for nearly all reported use. These amounts are not reflected in the 1993 totals from the full Questionnaire. Prior to mailing the full RCRA 3007 Questionnaire, EPA attempted to contact all potential recipients of the Questionnaire to confirm the use of the chemical as a solvent. EPA was only partially successful in reaching all facilities prior to mailing the full Questionnaire. However, between the telephone calls prior to mailing and responses to the Questionnaire after the mailing, certain facilities were removed from the mailing list. The facilities removed either had closed (2 facilities), incorrectly reported chemicals used (2 facilities), discontinued use of the chemical (17 facilities), or incorrectly reported the chemical as being used as a solvent (4 facilities). After review of the full Questionnaire responses, the Agency determined that certain uses did not meet EPA's definition of solvent use. For example, 34,484 kg of the ethylene reported was actually used as a sterilant, which does not meet EPA's definiton of solvent use. Nearly all of the aniline reported (14,920,877 kg of the 14,978,397 kg reported) was used as a raw material that was consumed in the process. This also does not meet EPA's definition of solvent use. The same is true of diethylamine, where 62,163 kg of the total 64,638 kg reported was actually diethanol amine rather than diethylamine. Finally, variations in usage are to be expected. In the case of 1,4-dioxane, five facilities reported higher use in 1992 than in 1993. For other solvents, facilities reported either increases or decreases in use between 1992 and 1993 that indicate changes in production schedule or product slate. EPA is confident that all large users of the seven solvents were identified and surveyed as part of the listing determination. The Agency believes that the solvent use reported in response to the full Questionnaire provides a more accurate characterization of solvent use patterns than the Preliminary Questionnaire because of the greater level of detail provided by the respondents. Finally, it is important to recognize that smaller uses of some solvents were captured through facilities reporting larger uses of other solvents. For example, Unocal, Rodeo, CA is a significant user of phenol, but also uses a small amount (3.86 kg) of aniline, thus information on acetonitrile wastes were collected. Table 2-2 presents the total reported use, by solvent, for each year along with an explanation of the reasons for the apparent changes in total use. Table 2-3 and Table 2-4 present and discuss the industry study identification and characterization of large-solvent users for each of the seven target chemicals. 3.0 Data Management and Waste Management Practices 3.1 Data Management and Analyses Data from the questionnaire were managed through a linked database system. From the data, EPA developed spreadsheets detailing residuals as reported by responders for each of the seven chemicals. Each residual stream reported by responders was evaluated to determine whether the residual represented a waste or an in-process stream. Residuals that were returned to the process through a closed loop system were excluded from further analysis. The Agency completed an enormous task in the data gathering effort. Thesedata helped EPA to identify the major waste generators. The questionnaire asked for very detailed information on waste generation, management, and disposal for these chemicals when they are used as solvents. The questionnaire was sent to larger facilities because 1) only large facilities would be likely to have on-site treatment, storage, and/or disposal for which questionnaire items would be applicable, and 2) many of the solvent uses are peculiar to large chemical industries and are not likely to be used in small companies. Thus, by applying a careful, consistent definition of solvent use and closely examining facilities that use these chemicals as solvent, the Agency identified where these chemicals are used as solvents, and where wastes of interest are generated and managed. Data submitted by TSDRs indicate that the original use of the chemical was unknown. Therefore, it was not possible to determine whether the residuals managed by TSDRs would be solvent use residuals. EPA noted that in preliminary questionnaire responses and again in full questionnaire responses, TSDRs reported the management of greater quantities of some chemicals than were identified by industry respondents. Generally, EPA believes that this indicates the management of wastes generated from non-solvent uses. Since separation of wastes from solvent and non-solvent uses was not possible at TSDR facilities, EPA could not assess management of these wastes with sufficient confidence in the accuracy of the results. Therefore, the Agency chose not to include residuals reported by TSDR facilities in the assessment of waste generation and management. The remaining residuals were deemed to be wastes generated as a result of solvent use. Based on the quantity of residual generated and the concentration of the solvent in the residual, EPA determined the loading of the solvent in the residual as Solvent Residual Quantity x Solvent Concentration = Solvent Loading All residual quantities were converted to kilograms and all solvent loadings were expressed in kilograms as well. Where liquid measurements were provided (e.g., liters or gallons), EPA used the specific gravity of the solvent for conversion of the units. Table 3-1 presents the specific gravities used for these calculations. 3.2 Identification of Current Waste Management Practices The current waste management practices were noted, including whether the residual was managed as hazardous at the time of the Questionnaire. Given the information the Agency has collected on these solvents, their uses, waste generation, and management, the Agency has a clear picture of the situation that exists with respect to environmental consequences of current management of these wastes. The Agency also does not believe management practices for these wastes are likely to change for a number of reasons: 1) facilities are not likely to abandon investment in capital equipment such as incinerators, tanks, or wastewater treatment systems, 2) many of these wastes are treated in some ways because they have value (recycling/reuse and BTU value as fuel), 3) facilities have incentives to try to recover more solvent, use a different solvent, or eliminate waste based on cost of solvent and reporting requirements (e.g., TRI), and 4) in the cases where wastes are already hazardous (by characteristic or mixture with a listed waste), the facilities do not have the option of changing to an unregulated management practices. In addition, many states have restrictions on management of liquid wastes in land-based facilities or the construction of surface impoundments (even non-hazardous ones) that make these options highly unlikely to occur. 4.0 Discussion of Solvents Study Chemicals 4.1 Allyl Chloride Ally chloride is produced by high-temperature chlorination of propylene, with dichloropropanes and dichloropropenes formed as by-products. Allyl chloride is an intermediate to crude epichlorohydrin, which is used to produce synthetic glycerin or refined to a purer product for synthesis of other products, such as epoxy resins. Other non-solvent uses include use in the pharmaceutical field as a raw material for the production of allyl isothiocyanate (synthetic mustard oil), allyl substituted barbiturates (sedatives) and cyclopropane (anesthetic). Allyl chloride also has been used to prepare allyl esters of starch, which are of some interest on surface coatings, and in the manufacture of speciality resins for water treatment. EPA has identified SIC codes through Chemical Abstracts searches that indicated potential use of the chemical as a solvent. These potential uses were cross-referenced with TRI data for this chemical reported to be "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. The literature search conducted for this study indicated that allyl chloride can be used in a solvent mixture for removal of deposits from reservoirs and tanks used for storage of heavy petroleum products. TRI data indicated that the Chemical and Allied Products industry may utilize allyl chloride for ancillary purposes. Of three facilities responding to the Preliminary Questionnaire, one confirmed use of solvent for biological research, and the other two could not confirm solvent use. The 1993 RCRA 3007 Questionnaire reported allyl chloride use as a solvent by four laboratory research and development facilities, totaling 12.0 kg. Allyl chloride was reported as having multiple laboratory uses, including chemicals synthesis by substitution. The use of allyl chloride in a solvent mixture for the removal of deposits from reservoirs and tanks and its use for ancillary purposes, uses identified in the literature search, were not confirmed in the 1993 Questionnaire responses. Table 4-1 presents the facilities reporting use of allyl chloride as a solvent. Table 4-2 presents solvent use by industry sector. 4.1.1 Wastes From Use as a Solvent All of the Wastes generated from the use of allyl chloride as a solvent are small volume, commingled organic laboratory wastes. Only two wastes of the four reported were larger than 3,000 kg/yr (with the largest volume wastes at approximately 12,397 kg/yr and 5,000 kg/yr). The remaining waste quantities were 40.91 kg/yr (with volumes not reported for the remaining waste stream). The total 1993 consumption of allyl chloride reported by each facility ranged from 1.10 kg to 7.26 kg. These low consumption rates result in total allyl chloride loading quantity of less than 12 kg. Table 4-3 presents the residuals generated by waste type. 4.1.2 Management Practices Each of the four organic wastes containing allyl chloride generated from its use as a solvent are managed either by on- or off-site incineration or off-site fuel blending. Most facilities employ on-site storage. The four wastes represent a total waste volume of approximately 17,438 kg and the allyl chloride concentration in the waste streams range from 11 ppm to 1%. The overall loadings was low, totaling less than 12 kg/yr. In all cases the wastes are managed as RCRA hazardous wastes; three of the four wastes are labeled as D001 (ignitable), one is D002 (corrosive), and the remainder consist of D-codes and several F-codes. Prior to final disposal or management, three of the spent solvent waste streams are managed in on-site containers (the fourth being stored off-site). One facility's residual volume and concentration was not reported. However, through conversations between the Agency and the facility, it was determined that the waste is managed as hazardous and sent for offsite fuel blending. An assumption was made that the total amount of allyl chloride used is passed through to the waste loading. Table 4-4 presents the statistics for the residuals, by management practice. 4.1.3 Health Data Allyl chloride (C3H5Cl, CAS No. 107-05-1), is a colorless to yellowish brown liquid with a pungent, unpleasant odor. It is extremely flammable, has a low boiling point (45 C), a flash point of - 25 F (by tag closed cup testing), and vapors that are more dense than air.12 It hydrolyzes in water with a half-life of 44 hours at 35 C. Flammable mixtures can be formed at ambient temperatures.12 Upon combustion, allyl chloride produces hydrogen chloride and/or phosgene and carbon monoxide.12 Allyl chloride is severely irritating to the eyes, skin, nose, throat, and respiratory tract. If inhaled, allyl chloride can produce liver, kidney, lung, and peripheral nerve damage.14 If ingested, allyl chloride can result in liver and kidney damage or death. Based on exposure data, the following exposure limits have been established for allyl chloride. The OSHA PEL and ACGIH TLV is 1 ppm (3 mg/m3)., The OSHA and ACGIH STEL limits are 2 ppm.15, 16 The NIOSH IDLH is 250 ppm, and the threshold odor level is 0.2 pm.15 Toxicity data indicate that acute exposure to allyl chloride can cause unconsciousness, while chronic exposure can cause cumulative liver and kidney damage. The established LD50 for acute exposure in rats via the oral route is 700 mg/kg and via the inhalation route is 11 gm/m3/2H. Allyl chloride is readily absorbed through the skin and is a possible human carcinogen. The RfC for allyl chloride is 0.001 mg/m3 based on a No Observable Adverse Effects Limit (NOAEL) of 3.6 mg/m3 for rabbits. Due to the small number of animals involved in the study and poor reporting of results for NOAEL exposure, EPA has low confidence in the study used as the basis for the RfC.20 Allyl chloride is rated as an EPA Group C (possible) carcinogen.20 Although no human cancer data were found, animal studies show the potential for cancer by gavage and skin painting.20 No RfD has been established. Aquatic toxicity has been estimated at 48 ppm for guppies exposed over a 96-hour period in fresh water.19 4.2 Aniline Seventy-four percent of the aniline produced in the U.S. is consumed as an intermediate in production of 4,4-Methylenebis(phenylisocyanate) (MDI). Future demand of aniline is expected to be linked to MDI production, which itself is forecast at a growth rate of 3-5% for 1990-1995. EPA has identified SIC codes through Chemical Abstracts searches that indicated potential use of the chemical as a solvent. These potential uses were cross-referenced with TRI data for this chemical reported to be "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. Literature searches indicate that aniline can be used as a solvent for conversion of coal to a liquid, specifically, for low-temperature coal liquefaction in basic nitrogen compounds; thermal dissolution of Fan-Yagnob coal; and extraction and reaction of coal below 100 C. Literature searches indicate that aniline may be used as a solvent in the dye industry to pretreat polyester fibers. The pretreatment is performed at a temperature range of 70 to 100 C in order to increase the dyeability of the fiber. It is assumed that only a portion of the organic solvent used to pretreat the fiber interacts with the fiber and therefore, a spent solvent would result. The 1993 RCRA 3007 Questionnaire reported use of aniline as a solvent by seven facilities totaling 20.38 kg. These facilities include three pharmaceutical manufacturers, one industrial organic chemicals manufacturer, one petroleum refinery, one office machines manufacturer, and one commercial physical and biological research facility. All seven facilities use aniline as a solvent for laboratory purposes, such as acetic acid titration of raw materials, testing properties of hydrocarbon solvents, and as a reaction or synthesis media for a dye intermediate filtrate. The use of aniline as a solvent for the conversion of coal to a liquid or in the dye industry to pretreat fibers, as indicated by the literature search, was not confirmed by the Questionnaire. Table 4-5 presents the facilities reporting use of aniline as a solvent. Table 4-6 presents the use of aniline as a solvent by industry. 4.2.1 Wastes From Use as a Solvent All of the wastes generated from the use of aniline as a solvent are small volume commingled organic laboratory wastes. Only two wastes of the seven reported were larger than 3,000 kg/yr (with the largest volume waste approximately 12,397 kg/yr and the second highest approximately 5,000 kg/yr). One facility reported an aniline waste stream of approximately 207 kg/yr, while the remaining estimations were less than 10 kg/yr. The total 1993 consumption rates result in a total aniline loading quantity of less than 14 kg. One facility did not report their residual volume or concentration. An assumption was made that the total amount of solvent used is passed through to the waste loading. Table 4-7 presents data on the generation of aniline residuals, by waste type. 4.2.2 Management Practices Each of the seven organic wastes containing aniline generated from its use as a solvent are managed in one of three ways: 1) stored on-site prior to being incinerated on-or off-site, 2) stored on-site prior to being sent off-site for fuel blending, or 3) in the case of the aniline stream being treated as "non-hazardous", treated at an on-site in a tank-based waste water treatment system. The seven wastes represent total waste volume of approximately 17,614 kg and the aniline concentration ranges from 23 ppm to 100%. Where high volume waste streams were reported, there were considerably low concentrations of aniline. Conversely, where low volume waste streams were reported, there were relatively high concentrations of aniline. Hence, the overall loadings was considerably low, totaling less than 14 kg/yr. In all but one facility, the wastes are managed as RCRA hazardous wastes: two of the seven wastes are labeled as D001 (ignitable) only; one is D002 (corrosive) only; one is toxic and ignitable; one is a U-listed wastes; and one carries various D- and F-codes. Prior to final disposal or management, the spent solvent wastes are managed in on-site containers or tanks. Table 4-8 presents data on the residuals generated, by management practice. 4.2.3 Health Data Aniline (C6H7N, CAS No. 62-53-3) is an oily liquid that is colorless when distilled but darkens to red-brown on exposure to air and light. It has a high boiling point (184 C) and a flash point of 169 F (closed cup). Various exposure limits have been established for aniline. The OSHA PEL and ACGIH TLV levels for inhalation are 5 ppm and 2 ppm, respectively.23, 27 The NIOSH IDLH level is 100 ppm. The threshold odor level is 1 pm.27. Toxicity data indicate that aniline is poisonous by most routes including inhalation and ingestion. Acute exposure may result in cyanosis and methemoglobinemia. Chronic exposure may result in anemia, anorexia, weight loss, and lesions.28 Via the oral route in rats the LD50 for acute exposure is 250 mg/kg. Aniline has a carcinogen slope factor (CSF) of 5.7E-03 mg/kg/day and a health-based limit (HBL) of 6E-03 mg/L. Toxicity data indicate that acute exposure to aniline can cause unconsciousness, while chronic exposure can cause cumulative liver and kidney damage.28 The established LD50 for acute exposure in rats via the oral route is 250 mg/kg and by inhalation is 250 ppm/4H.29 Aniline is readily absorbed through the skin and is a possible human carcinogen. The RfC for aniline is 0.001 mg/m3 based on spleen toxicity in rats.30 Due to the small number of animals and single exposure concentration used in one study and the short duration of a second study, EPA has low confidence in the study used as the basis for the RfC.30 Aniline is rated as an EPA Group B2 (probable) carcinogen.30 Human cancer data are not sufficient to demonstrate that aniline is a carcinogen, but animal studies show the potential for spleen and body cavity tumors.30 No RfD has been established. Aquatic toxicity shows that sunfish exposed at 1020 ppm over a 1-hour period in fresh water were killed. 4.3 Diethylamine Fifty percent of diethylamine consumed is used for the production of N,N-Diethylaminoethanol (DEAE). Diethylene amine based rubber accelerators include various N,N-diethyldithiocarbamate salts from Uniroyal Chemical, RT Vanderbilt, and ARTEL Chemical. Diethylamine is used to produce N,N-diethyl-m-toluamide (DEET). Diethylamine is used as a selective solvent for the removal of impurities from oils, fats, and waxes where its property of hydrating in aqueous solution is utilized. Diethylamine mixture is used as a mobile phase solvent for the optimization of TLC separations of basic drugs and alkaloids. Diethylamine mixture was used to test the solubility and reactivity of native, mercerized, and regenerative celluloses, as well as dissolution of cellulose in mixtures of N-methylmorpholine N-oxide. A sulfur dioxide/diethylamine/dimethyl sulfoxide mixture is used for viscosity measurements of cellulose to determine the molecular weight of cellulose in wood pulp. Diethylamine mixture is used as a solvent for the preparation of amorphous cellulose by regeneration of cellulose in its solutions. Diethylamine is used as a solvent medium for the preparation of the red-blue a-modification of copper phthalocyanine. [The red-blue pigment is useful for coloring oil varnishes.] A diethylamine mixture is used as a solvent in the reagent to dissolve iron protoporphyrins in fecal occult blood tests. Diethylamine is used for the cleavage of DNA and as a medium to study the dropping Hg electrode polarographic behavior of sulfur solutions. The 1993 RCRA 3007 Questionnaire reported diethylamine use as a solvent by 12 facilities, totaling 41.65 kg. All of the facilities indicated that diethylamine was used only in their laboratories. Eight of these facilities are pharmaceutical laboratories. Three of the pharmaceutical laboratories use diethylamine in chromatography; one uses it in a quality control lab; one uses the chemical as a solvent for amine reactions; and the others have multiple laboratory uses of diethylamine. In the industrial organic chemicals industry, there are two facilities which use the diethylamine for laboratory use. Finally, one laboratory in the office machines industry and one laboratory in the commercial research industry use diethylamine as a solvent. Several of the solvent uses identified in the literature search are being used according to the Questionnaire responses, but at the present time they are only being used on the research/laboratory level. Table 4-9 presents the facilities reporting the use of diethylamine as a solvent. Table 4-10 presents the solvent use by industry. 4.3.1 Wastes From Use as a Solvent All of the wastes generated from the use of diethylamine as a solvent are small volume commingled organic laboratory wastes. Only three wastes of the 13 reported were larger than 3,000 kg/yr (with the largest volume waste approximately 12,400 kg/yr). All of the remaining waste quantities were less than 210 kg/yr (with volumes not reported for four waste streams). The total 1993 consumption of diethylamine reported by each facility ranged from <0.01 kg to 14.12 kg. These low consumption rates result in a total diethylamine loading quantity of less than 41 kg. Table 4-11 presents data on the diethylamine residuals generated, by waste type. 4.3.2 Management Practices Each of the 13 organic wastes containing diethylamine are managed in one of three ways: 1) incineration on-site or off-site, 2) stored on-site prior to being sent off-site for fuel blending, or 3) burned for energy recovery. The 13 wastes represent a total waste volume of approximately 21,286 kg and have an average diethylamine concentration of 543 mg/L. In all cases, the wastes are managed as RCRA hazardous wastes; six of the thirteen wastes are labeled as D001 (ignitable), one is D002 (corrosive), one is F003/F005, two are a combination of D001, D018, and F001-F005, and three are unspecified hazardous wastes. Prior to final disposal or management, the spent solvent wastes are managed in on-site containers or tanks. Table 4-12 presents statistics for diethylamine residuals, by management practice. 4.3.3 Health Data Diethylamine (C4H11N, CAS No., 109-89-7) is a colorless liquid with a fishy, ammonia-like odor. It is highly volatile (explosive), has a low boiling point (55.5 C) with vapors more dense than air.35 It is harmful if ingested or inhaled and can burn eyes and skin.35 Various exposure limits have been established for diethylamine. The OSHA PEL dermal exposure limit is 25 ppm and the NIOSH IDLH limit is 200 ppm. The ACGIH TLV is 5 ppm (15 mg/m3) and the short term TLV is 15 ppm (45 mg/m3). Toxicity data indicates that diethylamine is a skin and eye irritant; and is moderately toxic by ingestion, inhalation, and dermal contact. Data indicate that acute exposure to diethylamine can cause eye, skin, mucous membrane, and respiratory tract irritation; diethylamine is corrosive and can severely damage skin and eyes.38 Chronic exposure can cause tracheitis, bronchitis, preunomitis, and pulmonary edema.38 Via the oral route in rats the LD50 is 540 mg/kg and the LC50 for exposure via the inhalation route is 4,000 ppm/4H.38 A reference dose (RfD), a carcinogen slope factor (CSF), a health based limit (HBL), or a maximum contaminant level (MCL) have been established for diethylamine. Aquatic toxicity has been estimated at 85 mg/l for creek chub exposed over a 48-hour period in fresh water. 4.4 1.4-Dioxane EPA has identified SIC codes through Chemical Abstracts searches that indicated potential use of the chemical as a solvent. These potential users were cross-referenced with TRI data for this chemical reported to be "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. 1,4-Dioxane is used as a solvent for extracting animal and vegetable oils and in the formulation of inks, coatings, and adhesives. In the laboratory, 1,4-dioxane is useful as a cryoscopic solvent for molecular mass determinations and as a stable reaction medium for diverse reactions. 1,4-Dioxane is used primarily as a solvent in such widely used products as paints, varnishes, lacquers, cosmetics, deodorants, cleaning and detergent preparations, and in scintillating fluids. Literature searches also indicated the potential for use as a solvent in the processing of crude petroleum, petroleum refining, petrochemicals, pulp and paper, explosives, commercial printing, electroplating/polishing, pesticide and agricultural manufacture, dyes, fiber manufacture, pharmaceuticals, adhesives, semiconductors, electronic components, photographic equipment, magnetic recording media, polymers, plastics, rubber manufacture, and organic and inorganic chemical manufacture. The 1993 RCRA 3007 Questionnaire reported 1,4-dioxane use as a solvent in 27 facilities, totaling 101,577.08 kg. Only one facility in the coated and laminated paper industry indicated the use of 1,4-dioxane. The chemical was used in the dissolution of polymers to produce a coating. Sixteen pharmaceutical facilities reported the use of 1,4-dioxane, fourteen of which use the small amounts of the chemical in laboratory operations such as research and development, quality control of finished goods, and laboratory experiments. The remaining two facilities use 1,4-dioxane as a medium for crystallization and for the distillation and dissolution of an intermediate product. Three facilities in the organic chemicals industry use 1,4-dioxane. One facility uses small amounts of 1,4-dioxane in a quality assurance laboratory; one facility uses it for distillation and as a reaction/synthesis medium; and the third facility uses 1,4-dioxane for chromatography in polyolefin catalyst synthesis. The largest use of 1,4-dioxane is by a pesticide and agricultural chemical facility. This facility uses the chemical as a polar reaction medium for a nucleophilic displacement reaction. Both the facility in the chemical preparations industry and the petroleum refining industry use minimal amounts of 1,4-dioxane. The chemical preparations facility uses 1,4-dioxane as a reaction medium in the laboratory. The petroleum refining facility uses it at a concentration of 1% in a cleaning solvent. One facility uses 1,4-dioxane in the office machines industry for the dissolution of pigment for an interface spray. In the photographic industry, there are two facilities which use 1,4-dioxane; one facility uses it to dissolve resins and polymers into solution for film coating; the other facility uses 1,4-dioxane as a photochemical reaction/synthesis medium as well as for miscellaneous research and development projects. Finally, one facility in the commercial research industry uses 1,4-dioxane in its laboratories as a solvent in reactions and distillation. The use of 1,4-dioxane in the processing of explosives, dyes, fiber manufacture, semiconductors, and rubber manufacture, uses identified in the literature search, were not reported in the 1993 Questionnaire responses. Table 4-12 presents the facilities reporting the use of 1,4-dioxane as a solvent. Table 4-13 presents the use of solvent, by industry. 4.4.1 Wastes From Use as a Solvent The wastes generated from the use of 1,4-dioxane as a solvent are organic wastes, waste waters, and solids. The majority of the waste streams (39 of the 48) are in the form of organic wastes, and they vary from the smallest volume of 0.1 kg to the largest volume of 297,000 kg. These facilities reported 1993 consumptions of 1,4-dioxane in the range of 0.45 kg to 54,000 kg. Seven of the waste streams are wastewaters. The wastewater streams range from 356 kg to 206,000,000 kg. The 1993 use of 1,4-dioxane was between 1 and 54,000 kg for the wastewater streams. Two wastes were reported as solids. The residual volumes were 12,000 kg and 554,000 kg, and the total 1993 1,4-dioxane consumptions were 3,850 kg for both streams. Table 4-14 presents data on the generation of 1,4-dioxane residuals, by waste type. 4.4.2 Management Practices The wastes containing 1,4-dioxane generated from the use of 1,4-dioxane as a solvent are managed in at least five different ways. The solids and organic wastes are managed in one of three ways: incinerated on-site or off-site, maintained on-site until they are burned off-site for energy recovery, or maintained on-site until they are sent off-site for fuel blending. The majority of the solid and organic wastes are incinerated. In all three cases, the waste streams are managed as RCRA hazardous wastes. There is one exception where a facility has non-hazardous on-site solids incineration. Seven of the 41 waste streams are labeled as D001; 18 are labeled as a combination of D001, D002, D018, D022, D028, D035, D038, F002, F003, F005, U003, U005, U007, and U188; and the remainder are unrecorded or disposed of by some other means. The wastewater streams are either sent to a POTW for treatment or are biologically treated on-site in a WWTP prior to being discharged. The wastewater streams are all managed as non-hazardous wastes and the wastewater treatment systems are tank-based. Table 4-15 presents statistics on the management of 1,4-dioxane residuals, by management practice. 4.4.3 Health Data 1,4-Dioxane (C4H802, CAS No., 123-91-1) is a colorless, flammable liquid with a faint, pleasant odor. It has a moderate boiling point (101 C) and a flash point of 5 to 18 C.44 Its vapors are heavier than air. Various exposure limits have been established for 1,4-dioxane. The limit for OSHA PEL is 100 ppm (360 mg/m3) with an assigned "skin notation" indicating that this chemical has the potential for dermal absorption. The ACGIH TLV for dermal exposure is 25 ppm and 90 mg/m for inhalation. The NIOSH IDLH is 500 ppm.46 Toxicity data indicate that acute exposure to 1,4-dioxane can cause respiratory irritation, headache, nausea, vomiting, drowsiness, dizziness, and central nervous system depression. Chronic exposure can cause liver and kidney damage in animals.48 The established LD50 for acute exposure in rats via the oral route is 5,200 mg/kg. The LC50 for rats via the inhalation route is 46 gm/m3/2H.48 1,4-Dioxane is a probable human carcinogen. The carcinogen slope factor (CSF) for 1,4-dioxane is 0.011 mg/kg/day and the health based limit (HBL) at 10-6 risk level is 0.003 mg/L. A reference dose (RfD) and a maximum contaminant level (MCL) have not been established for 1,4-dioxane.51 1,4-Dioxane is rated as an EPA Group B2 (probable) carcinogen.51 Three epidemiological studies showed no relationship between exposure to 1,4-dioxane and human cancer.51 Animal studies show the potential for liver and nasal cavity cancer by ingestion.48 4.5 Ethylene Oxide A small fraction of ethylene oxide production (less than 0.5 percent) is consumed by a sterilant or fumigant users. Ethylene oxide is utilized as a sterling agent by various facets of the health care industry for the sterilization of delicate instruments and heat and moisture sensitive devices. (EPA 49 FR 25734). Such use does not meet EPA's definition of "solvent use." EPA has identified SIC codes through Chemical Abstracts searches that indicated potential use of the chemical as a solvent. These potential uses were cross-referenced with TRI data for this chemical reported to be "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. Potential solvent uses identified through literature searches include use as a solvent/catalyst in catalyst systems subjected to different stages of heat treatments in the skeletal isomerization of cyclohexane to 1-methylcyclopentene and 3-methylcyclopentene. The 1993 RCRA 3007 Questionnaire reported ethylene oxide use as a solvent by three pharmaceutical research laboratories, totaling 4.29 kg. In these laboratories, ethylene oxide had multiple small-scale solvent uses, such as a reaction or synthesis medium in oxidation and use as a standard for gas chromatography. The use of ethylene oxide as a solvent in catalyst systems in the skeletal isomerization of cyclohexane, a use identified in the literature search, was not reported in the 1993 Questionnaires. Table 4-16 presents the facilities reporting the use of ethylene oxide as a solvent. Table 4-17 presents the use of ethylene oxide as a solvent by industry. 4.5.1 Wastes From Use as a Solvent Most of the wastes generated from the use of ethylene oxide as a solvent are commingled organic laboratory wastes. The residual volumes reported range from 210 kg to 12,400 kg. The three waste volumes each had concentrations of much less than one percent. This resulted in all three loadings being under 3 kg, totaling 4.3 kg of ethylene oxide. Table 4-18 presents data on the quantity of ethylene oxide residuals, by waste type. 4.5.2 Management Practices Each of the three organic wastes containing ethylene oxide generated from the use of ethylene oxide are managed in one of two ways: onsite storage followed by either incineration or fuel blending. The three wastes represent a total waste volume of 17,611 kg and have concentrations ranging from 11 parts per million to 0.01 percent. In all cases, the wastes are managed as RCRA hazardous wastes and are labeled as D001 (ignitable). One of these three is also labeled D018 and F002/F003/F005. Table 4-19 presents statistics for the management of ethylene oxide residuals by management practice. 4.5.3 Health Data Ethylene oxide (C2H40, CAS No., 75-21-8) is a colorless gas condensing at low temperatures (below 12 C) to a mobile liquid, with a ether-like odor. Ethylene oxide is a highly reactive molecule with vapors that are flammable and explosive. It hydrolyzes in water with a half-life at 25 C of about 12 days. As little as three percent ethylene oxide in air can be flammable.54 Ethylene oxide has a very low boiling point (10.6 C) with vapors that are heavier than air.54 It may undergo hazardous polymerization upon contact with highly active catalytic surfaces.54 Based on exposure data the following exposure limits were established for ethylene oxide. The OSHA PEL limits for TWA and 15 minute excursion are 1 ppm and 5 ppm, respectively. The ACGIH TLV limits for TWA is 1 ppm. The ACGIH also reports an odor threshold of 261ppm for perception and 500 to 700 ppm for recognition.55 The NIOSH IDLH limit is 800 ppm and the threshold odor level is 1 pm.56 The NIOSH TLV limits for TWA and the ceiling are <0.1 ppm and 5 ppm, respectively. The toxicity data indicate that ethylene oxide is irritating to the skin, eyes, and mucous membranes of respiratory tract. Toxicity data indicate that acute exposure to ethylene oxide can cause nausea, vomiting, and death. Chronic exposure can cause irritation of eyes, skin, and mucous membranes, cataracts, and problems in brain function. Exposure to ethylene oxide may result in lung, liver, and kidney damage.58 Via the oral route in rats the LD50 is 72 mg/kg and via the inhalation route, the LC50 is 800 ppm/4H.58 Ethylene oxide is rated as a Group B1 (probable) human carcinogen. The carcinogen slope factor (CSF) is 1.02 mg/kg/day and the health-based limit (HBL) is 3E-05 mg/L.61 A reference dose (RfD) and a maximum contaminant level (MCL) have not been established for ethylene oxide.61 4.6 Bromoform Bromoform is reportedly used in separating mixtures of minerals, as a solvent to selectively extract rare earth metals (e.g., Cs and Rb), and to separate Ekibastuz coal into fractions (benefication). Non-solvent uses of bromoform include use in organic syntheses and in medicinal pharmaceuticals as a sedative. EPA has identified SIC codes through Chemical Abstracts searches that indicate potential use of the chemical as a solvent. These potential uses were cross-referenced with TRI data for this chemical reported as "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. 4.6.1 Use as a Solvent In response to the RCRA 3007 Preliminary Questionnaire, 12 facilities indicated the use of bromoform as a solvent at their site. These facilities reported a total use of 18,254 kilograms in 1992. Nearly all of the "use" was reported by TSD facilities that accepted bromoform for thermal treatment. Two facilities reported the use of bromoform in the RCRA 3007 Questionnaire of Solvent Use, one of which erroneously reported its use as a solvent, when in fact it was used as a reactant. The only facility to indicate the use of bromoform as a solvent used a very small amount, 0.001 liters per year. The facility did not report any residuals associated with this use due to the very small quantity involved. 4.6.2 Health Data Bromoform (CHBr3, CAS No., 75-25-2) is a colorless to yellow, very heavy liquid (density = 2.9031), with a chloroform-like odor. It is toxic by inhalation, ingestion, and skin absorption; is irritating to the skin, eye and respiratory tract.65 It is a lachrymator.65 It is non-flammable, has low reactivity, and has a moderate boiling point (149 C).65 Based on exposure data the following limits have been established for bromoform. The OSHA PEL and the ACGIH TLV are 5 mg/m3 (0.5 ppm) and 5.2 mg/m3 (0.5 ppm), respectively and a "skin notation" has been assigned, which indicates a potential for dermal absorption . The NIOSH IDLH limit is 850 ppm.66 Bromoform is moderately toxic via the oral and subcutaneous routes. Acute inhalation of small amounts causes irritation, provoking the flow of tears and saliva, and reddening of the face.22 Cumulative exposures cause liver damage and abuse of bromoform can lead to addiction.22 Acute exposure in rats via the oral route has a LD50 of 1,147 mg/kg and an LC50 via the inhalation route of 45 gm/m3/4H.68 Bromoform has a reference dose (RfD) of 2E-02 mg/kg/day, a carcinogen slope factor (CSF) of 7.9E-03 mg/kg/day, and a health-based limit (HBL) limit of 4E-03 mg/L at 10-6 risk level. An interim maximum contaminant level (MCL) of 0.10 mg/L has ben established for total trihalomethanes.69 No RfC has been established.69 According to IRIS, the inhalation unit risk value is 1.1E-06 (ug/m3)-1, and thus, the concentration in air corresponding to a risk level of 10-6 is 9E-04 mg/m3. 69 Toxicity data indicate that acute exposure to bromoform can cause central nervous system depression, while chronic oral exposure can cause liver, kidney, and central nervous system damage in animals.68 Bromoform is rated as an EPA Group B2 (probable) carcinogen.69 Although no human cancer data were found, animal studies show the potential for liver and intestinal cancer by oral exposure.69 4.7 Vinylidine Chloride Vinylidene chloride's major use is as an intermediate in the production of "vinylidene polymer plastics" such as Saran and Velon. It also is used captively for the production of 1,1,1-trichloroethane. EPA has identified SIC codes through Chemical Abstracts searches that indicated potential use of the chemical as a solvent. These potential uses were cross-referenced with TRI data for this chemical reported as "otherwise used." A complete description of this methodology is presented in Section 2.0 of this study. No solvent uses have been identified due to its reactivity. 4.7.1 Use as a Solvent Data from the RCRA 3007 Preliminary Questionnaire indicted that five facilities used a total of 24,532 kilograms of vinylidene chloride as a solvent in 1992, which included 24,529 kg reported by two TSDs. An additional 3 kg reported by two facilities did not meet EPA's definitions of "solvent use." One facility used less than 0.03 kg; this use was not continued in 1993. In response to the RCRA 3007 Questionnaire, the only "use" of vinylidene chloride was reported by a TSD facility that accepted vinylidene chloride for treatment. No other facilities reported the use of vinylidene chloride on the RCRA 3007 Questionnaire. The use of vinylidene chloride as a solvent appears to be very limited, if it even occurs. It is unlikely that it has any industrial solvent use, rather it is used for specialty applications in laboratories. 4.7.2 Health Data Vinylidene chloride (C2H2Cl2, CAS No., 75-35-4) is a colorless, mobile liquid with a sweet, slightly irritating odor resembling that of chloroform. It is toxic by ingestion or inhalation and is an eye and skin irritant.70 It is flammable and may undergo hazardous polymerization with atmospheric oxygen if its inhibitor has been depleted.70 It has a low boiling point (31.6 C) and a flash point of -15 C.70 Based on exposure data the following limits have been established for vinylidene chloride. The ACGIH TLV and STEL exposure limits are 5 ppm and 20 ppm, respectively. No exposure limits have been established for the OSHA PEL, NIOSH IDLH, and the threshold odor level. Toxicity data indicate that the vinylidene chloride is a skin and mucous membrane irritant.70 Toxicity data indicate that acute exposure to vinylidene chloride can have adverse respiratory and neurological effects (e.g., central nervous system depression, convulsions, spasms, and unconsciousness). Chronic exposure can cause cumulative live rand kidney damage.72 It has caused liver and kidney injury in experimental animals and is a narcotic at high concentrations.70 The established LD50 for acute exposure in rats via the oral route is 200 mg/kg and the LC50 for inhalation in rats is 6,350 ppm/4H.72 Vinylidene chloride is a possible human carcinogen. Vinylidene chloride has a reference dose (RfD) of 0.009 mg/kg/day, a carcinogen slope factor (CSF) of 0.6 mg/kg/day, and a health-based limit (HBL) of 6E-05 (corresponding to a risk level of 1E-06)71 and a maximum contaminant level (MCL) of 0.007 mg/L. EPA has medium confidence in the study used as the basis for the RfD.71 Vinylidene chloride is rated as an EPA Group C (possible) carcinogen.71 Although no relationship between occupational exposure to vinylidene chloride and human cancer were found, animal studies show the potential for kidney and mammary cancer by inhalation.71 The concentration in water corresponding to a risk level of 10E-06 as reported by IRIS is 6E-05 mg/l. The inhalation unit risk value is 5E-05 (ug/m3)-1, and thus, the concentration in air corresponding to a risk level of 10E-06 is 2E-05.71