.... • • • • • • • : ··.. - ·- A''•,,. • r � ,. - � � ·�. . .. t' Attachment �_f.. 9£. UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY WASHINGTON'. D.C. ao,,o ,.,,�".I,.• � ��.-��/.1 • • � • • IEP '' lie? • . . . -. Sll3JE:CT: Briefing Dx:ment for Septe,rber 27, 1982, at 11:00am on Region VII, Dioxin lasues . . ..., �;,c, o, aouo WASTI AND IMUIOIHC'f'. IIIPONII /J. fJ01 1 Conrad O. lleveno /) � Dioxin Q;,or,:,i� TO : • 1ti U H. La�lle Assistant "'1nliniatrator . / '1'he(€:iefin; �cb;e -1ncl�tbe f0llowing itms: � Agenc:a � Participent.a l, Aueument.a � �ak!Exp:,sure Auessment or �ion YlI Situ tr. l:lcnald l&rnes, Ol'IS b. aisle Aueument' . Jlt". �rt ��hy, Dinctar, QC �-Ass�t·at pthei' sites ·Ir •. Jlaxbara. ·El.Jcm , C&Wm �. laftls �- � 'JIil.lat.a, CSWER vc. �- · �r . 4. . �ons - lubara llJcill Y'7 IJl.-·.osp-tcoa ,aw. -1rca,a.. � 1111:b - JTos , a:m VC• 100 � ..� briefing •trdal ·-�•• v{': Jltgicn atatua at sites - Jlagion ax, IIU) � l'riarity lilt 1uuea - JISCD � Enforcenie2at CpUons ,t..atus of prcp:,sed ICM regulation - � l>ioxin �sk force aar.oranc,11:1 ;:i: n. L 473 : Other (M) •· � ion aaM9f!N11t plan b. a..te concuns tteno to DIT Chaiman c. Sturveon SpW · Jte� Jan:, • ..... , b.: � !M.jor oaeualion issues. 1he other • • - • - , .... ,.., ,.,,....... .-v1 ,.,.,..,,. tT,.- -- infom ation. --- 1859G . ,. . • . . , • • • OPTION1 ' . C�eanup to th• detection lintit of 0.01 - 0.05 ppb* • Conalatent vlth the cleanup levela in conaent deer••• at Byde Park, lyntex and Vertac. Conaiatent with luperfund level• of cleanup at Love Canal. Aa proteetl•• •• technologically possible. Conalatent with Agency atat•�enta on the bazarda of TCDD. CON1 Lik ely to be a ••ry oxpenai•• cleanup - absolute coat will be blgh - availability of disposal option• will be linited • Nay be •leved aa overkill lampllng coata are ••ry blgh. and procedures are till• consuming. • • aackground 1•••1• of TCDD int.he area aay be above 0.05 ppb,, ln vhich ea•• cleanup under t.hia option would be� tbe baek�round le•el. • 474 \ • 185�fi' ·. . . . .. .. ! .. i" ) .. • • .. • • • OPTION, V•• 1 ppb a• th• cleanup level for the preliminary actions (Preliminary injunction and/or planned removal actions) and.continue aialyaia to detennin• final acceptable cleanup level. •Ro, • Allova bmaediate action for Agency, and good pr•••· auya till• • Allova tlae for r••••••nent of Agency riak analyaia ••thoda and policiea, IAB reviev, and other acientific revlev. • Allows preparation of public for poaalble change in policy. lnt•raedlat• coat option Consi•t•nt with ••oaho order llemov•• •ajor aource of riak Saally lapleaented, aampling la relati••lf lnexp•n•i•e and •••Y llot t.b• final aolutlon, �be problem will be ongoing until final reaolutlon CONi � Jf final cleanup level la 1 ppb, then etlll bave lnconaiatency with cleanup level• at Hyde Park, lyntex,·vertac and tove Canal. la1ed on co1t and need for !aediate action, not total health protection. / 475 185�8 ,. . • • ... ., .. . ... . .. . .. ..' . .... .. . . - . . . • OPTIONa • • Uae 100 fPb •• a cleanup level. Thia Option could be uaed to buy time• am in Option III, though tf no action 11 taken, the position of the �ency that ve are conaidering other action ta likely to be lesa convincing. . . .. •osalbly no action or llaited action 1• needed at the ••os Bora• Arenas. There are higher rlaka iaken every day (e.g. noking). trovidea forUJ1 for any deaired policy change • ... .. CON: Could create extre�• political backlash. •ublic and pr••• acrutiny vill be aubatantial. Thia la an involuntary riak. Conflict• with previou1 guidance regarding bazarda of TCDD ea a carcinogen. Confiicta vi th prtvloua agency policy that rlaka above 10·5 to 10-6 are unacceptable • �. •..,.·. Conflict• vith filed ll0&(a) order at ••oaho, No., 'which require• cleanup of 8011 vlth 62 ppb of t'CDO • Conflict• vith cleanup level• agreed to in consent deer••• at lyde tark, lyntex, and vertac. Conflict• with luperfund cleanup le••l• at tove �anal. Conflict• vlth Nlaaourl ltate Court/ruling which g�anted . damage• to peraona expoaed to 22 ppb in aoll. ... . . ·' ' 476 • DRAFT Meeting No. 2 April 25, 1980 ,.•Jc, _,,,-,3Sll Sur�ary of the Chlorinated Dioxins Wrok Group (COWG} Meeting l 1. The attached agenda was distributed and followed. l 2. A draft summary of the April 18 meeting (No. 1 meeting) was distributed and comments requested. With one minor change the material is ready for final. 1 � I $f/1HU 3. At the TSPC meeting last Friday a brief mention was made of CDHG activities and our plans for dealing with Hempstead. It was thought to be inadv{sable to distribute the memo discussed at our last meeting since the directlv affected DAA 1 s had not yet been contacted. These matters: a. initial funding by OSW · b. more active participation by A{r programs have now bee1' handled directly. OSW has put forward $300K and Air has volunteered the services of Jack �cGinnity (FTS 629-5204). , • J\CTIO� ISSUE I I I' REFERRAL ! . .. ' 4. In order to �sue the· risk assessment in connection with Hempstead, Mike Dellarco should provide Wright'��nd RTP analytical data to Jack McGinnity (for plume modelling) and to Tom McLaughlin of CAG. i. Dropping the other shoe in the Vertac scbiy he started last week, Gordon Olson told us that the Section 6(d) hearing on Vertac's request for consdieration of 2,4-D prod·uction wastes would be Completed around ,1ay 1. The Agency has 10-days in which to render a final decision. The crux of the issue lies in the fact.that the 2,4-D wjlS.tes.. (' probably__<;:1?.i:ital!l...�... �-� ,J?E9 . .t;.iQ . 6(d� rule speaks of relatively small storage costs for such wastes, Vertac calculates that the cost of soring the corrisive 2,4-D wastes will be about $1�0,000 pir year. >J Further discussion reveal ed that OCC i� the proper group to consider the relative 'economic impacts and the Dioxin Task Force (DTP) is the proper group to suggest alternatives for handling the wastes. Therefore, this matter was referred to OCC (Gordon )lson) and DTF (R.uss Wyer) for immediate attention in order to develop an AGency position by may 12. 6. Rich Smith brought the CDWG up to date on the civil 1' I I ISSUE STATUS suit against VErtac, which deals with their water basin, leaching, other matters not directly �elated to the barrels. The suit seeks to el minate any TCDD in process waters, to cap and monitor soit--contaminated areas, and to institute best eng¢neering practes at the facility. In considering the problem the judge will�obably inquiry about the status of the 2,4,5-T { 7. Gordon Olson reports ·that Vertac no longer speaks of its "TCDD destruct process" in terms of. tea ting the 2, 4, 5-T w�s tes, but �ather in terms of destry'oing any TCDD that might occur in 2,4,5-T itself. I 8. In an addition to the old business items on the agenda Paul dcsRosier reported �t Hooker has been told that it should treat the dioxin contaminated land around �loody Run with the same level of precaution as it Hould with '· a plutonium contamination problem. Estimated cost: $5-10 million­ Th� alternative--capping 1n-�Iace--would be much less expensive. ---< 9. The relationships between TSPC CD�-IG ,· DTF, and Dioxin Sources J Sub-group (DSS) were explained. See attachment. lo. Russ Wyer, newly appointed chairman of the DTF, explained the plans of his group. AFter gaining experience by teating problems associated with certain specific sites, the DTF will develop general �uidance and policies designed to deal with the majority of dioxin-relateq situations. The DTF will be a small group involving OPTS, ORD, OSW and OHWETF. This core� be su�plemented by expertise within and outside the AGency as needed. ACTio:.; 11. Don Barnes will draft guidance for the Regions, d�cribing tFie procedures whfh should be followed in "otifying and requesting assistance from tfadquarters. The COW<; wi.11 be notifie� with the DTP providing the single technical voice responding to each such request. This guidance will be issued on behalf of the TSPC or the Administrator's office. 12. The stcTus of the Dioxin Sources Sub-group (DSS) was reviewed. a. Its first meeting was held 9n April 24; minu�� are availableb. CDWG members asked the DSS �Q be aware of the presence of trichlorophenol (TCP), a bactericide, in the make-up water and the boiler water of the plant. c. The need for interim guidance for the resource recovery industry and other members of the public was discussed. Such Guidance should refer to related research in this country and abroad which indicates the need for high temperatures and high residence times in order to minimize dioxin formation. In addition, considerable evidence points to the fact that dioxin formation in combustion is directly related to the presence of dioxin precursors in the feedstock. Jack S huckelford and OSW will draft such guidance and circulate ,_to the members of ACTION it. CDWG. \ 478 THE WONDERFUL WORLD OF DIOXINS You can't tell the players without a program Toxic Substances priorities Committee (TSPC) Chlorinated Dioxins Work Group (CDWG) Dioxin Task Force (DTF) Dioxin sources Sub-group (DSS) DTP DSS TSPC: AA's aAd DAA's of the agency who collectively examine cross-cutting isues related to toxic substances CDWG: Intragency work group established to k·eep abreast of issuesrealted to chlorinated di9xins and to recommend policies for the agency. Reports to TSPC. DTF: Established by TSPC to handle site specific dioxin related o ).� issuesf'hrecomrnend procedures and policie� by which· future situations can be deiil!t with. Reports to CDWG. DSS: Established to deal with specific problems associated with Hempstead, Long Island incinerator, more general question of resource recovery incinerators, and the overall question of all large scale combustion processes. Reports to CDWG. 479 1704;)