Chlorinated Aliphatics Industry Overview

United States Office of
Environmental Protection Solid Waste

Agency Washington, D.C. 20460 July 30, 1999
Listing Background
Document for the
Chlorinated Aliphatics
Listing Determination
(Proposed Rule)
FINAL
Prepared For:
U.S. ENVIRONMENTAL PROTECTION AGENCY

Office of Solid Waste
Hazardous Waste Identification Division
401 M Street, SW
Washington, DC 20460
Prepared By:
Science Applications International Corporation

Environmental and Health Sciences Group
11251 Roger Bacon Drive
Reston, VA 20190
HAZARDOUS WASTE MINIMIZATION AND MANAGEMENT

DIVISION TECHNICAL SUPPORT CONTRACT
EPA Contract No. 68-W98-025, WA No. 1-21

TABLE OF CONTENTS Page Number
1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Existing Chlorinated Aliphatics Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.3 Other EPA Regulatory Programs Affecting The Chlorinated Aliphatics Industry
.............................................................4
2. INDUSTRY DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1 Chlorinated Aliphatics Industry Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.1 Industry Study Profile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.2 Recent Developments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.2 Industry Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
2.2.1 Engineering Site Visits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
2.2.2 RCRA Section 3007 Questionnaires . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
2.2.3 Familiarization Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
2.2.4 Record Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3. MANUFACTURING AND WASTEWATER TREATMENT PROCESS DESCRIPTIONS

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3.1 Chlorinated Aliphatics Manufacturing Processes . . . . . . . . . . . . . . . . . . . . . . . . 25
3.1.1 Ethylene Dichloride (EDC or 1,2-dichloroethane) and Vinyl Chloride
Monomer (VCM or chloroethene) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
3.1.2 Vinyl Chloride Monomer Using Acetylene as a Raw Material (VCM-A)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
3.1.3 Methyl Chloride . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
3.1.4 Allyl Chloride . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
3.1.5 Other Chlorinated Aliphatic Manufacturing Processes . . . . . . . . . . . . . . 36
3.1.6 Manufacturing Processes That Do Not Generate Wastewater . . . . . . . . 43
3.2 Waste Treatment Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
3.2.1 Biological Wastewater Treatment Systems . . . . . . . . . . . . . . . . . . . . . . 43
3.2.2 Non-biological Wastewater Treatment Systems Discharging to NPDES
Permitted Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
3.2.3 Non-Biological Pretreatment Processes Prior to POTW/PrOTW Discharge
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
3.2.4 Underground Injection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
4. WASTE GROUPINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
4.1 Wastewaters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
4.1.1 Proposed No-List: Wastewaters Generated from the Production of Vinyl
Chloride Monomer Using Mercuric Chloride Catalyst in an Acetylene-
Based Process (VCM-A Wastewaters) . . . . . . . . . . . . . . . . . . . . . . . . . 47
Chlorinated Aliphatics Listing Determination

Background Document, Version 1 i July 30, 1999
4.1.2 Proposed K173: Chlorinated Aliphatics Wastewaters, excluding VCM-A
Wastewaters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
4.2 Wastewater Treatment Sludges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
4.2.1 Proposed K174: EDC/VCM Wastewater Treatment Sludges, excluding
VCM-A Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
4.2.2 Proposed K175: VCM-A Wastewater Treatment Sludges . . . . . . . . . . 63
4.2.3 Proposed No-List: Methyl Chloride Wastewater Treatment Sludges . . . 65
4.2.4 Proposed No-List: Allyl Chloride Wastewater Treatment Sludges . . . . 68
Appendix A. RCRA Section 3007 Questionnaire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Appendix B. EPA Record Sampling Analytical Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119
Appendix C. Industry Split Sample Comparison with EPA Record Sample Data . . . . . . . . . . 173
Appendix D. Summary of Waste Generation and Management Practices . . . . . . . . . . . . . . . . 195
Appendix E. Summary of Chlorinated Aliphatics Manufacturers . . . . . . . . . . . . . . . . . . . . . . 203

Background Document, Version 1 ii July 30, 1999
LIST OF FIGURES AND TABLES Page Number
Table 1-1. Existing Chlorinated Aliphatics Listed Hazardous Wastes . . . . . . . . . . . . . . . . . . . . 3
Table 1-2. Chlorinated Aliphatic Toxicity Characteristic (TC) Hazardous Wastes . . . . . . . . . . . 3
Figure 2-1. Geographical Distribution of Chlorinated Aliphatics Manufacturers . . . . . . . . . . . . 8
Table 2-1. Frequency of Manufacturing Processes within the Chlorinated Aliphatics Industry
(1996 Data) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Table 2-2. Products/Processes at Chlorinated Aliphatics Facilities (1996 Data) . . . . . . . . . . . . 10
Table 2-3. EDC Production Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Table 2-4. VCM Production Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Table 2-5. Methyl Chloride Production Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Table 2-6. Perchloroethylene Production Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Table 2-7. VCM Production Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Table 2-8. Engineering Site Visits Conducted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Table 2-9. Familiarization Samples Taken . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Table 2-10. Representativeness of the Record Sampling Program . . . . . . . . . . . . . . . . . . . . . . 22
Table 2-11. Samples Collected for Record Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Table 3-1. EDC/VCM Manufacturers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Figure 3-1. Generic EDC/VCM Balanced Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Table 3-2. Methyl Chloride Manufacturers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Table 3-3. Chlorinated Methanes Manufacturers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Figure 3-2. Chlorinated Methanes Process Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Table 4-1. Waste Generation Statistics for VCM-A Wastewaters . . . . . . . . . . . . . . . . . . . . . . . 47
Table 4-2. Waste Management Statistics for VCM-A Wastewater . . . . . . . . . . . . . . . . . . . . . . 47
Table 4-3. Waste Characterization Data for VCM-A Wastewaters . . . . . . . . . . . . . . . . . . . . . 49
Table 4-4. Waste Generation Statistics for Chlorinated Aliphatics Headworks used in the Risk
Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Table 4-5. Waste Management Statistics for Individual Chlorinated Aliphatics Wastewaters . . 50
Table 4-6. Selection of Risk Assessment Modeling Scenarios: Chlorinated Aliphatics Wastewaters 51
Table 4-7. Waste Characterization Data for Chlorinated Aliphatics Wastewaters . . . . . . . . . . . 53
Table 4-8. Waste Generation Statistics for EDC/VCM Sludge . . . . . . . . . . . . . . . . . . . . . . . . . 58
Table 4-9. Waste Management Statistics for EDC/VCM Sludge . . . . . . . . . . . . . . . . . . . . . . . 59
Table 4-10. Selection of Risk Assessment Modeling Scenarios: EDC/VCM Sludge . . . . . . . . . 59
Table 4-11. Waste Characterization Data for EDC/VCM Sludges . . . . . . . . . . . . . . . . . . . . . . 60
Table 4-12. Waste Generation Statistics for VCM-A Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . 63
Table 4-13. Waste Management Statistics for VCM-A Sludge . . . . . . . . . . . . . . . . . . . . . . . . . 63
Table 4-14. Waste Characterization Data for VCM-A Sludge . . . . . . . . . . . . . . . . . . . . . . . . . 64
Table 4-15. Waste Generation Statistics for Methyl Chloride Sludge . . . . . . . . . . . . . . . . . . . . 65
Table 4-16. Waste Management Statistics for Methyl Chloride Sludge . . . . . . . . . . . . . . . . . . 66
Table 4-17. Selection of Risk Assessment Modeling Scenarios: Methyl Chloride Sludge . . . . . 66
Table 4-18. Waste Characterization Data for Methyl Chloride Sludges . . . . . . . . . . . . . . . . . . . 67
Table 4-19. Waste Generation Statistics for Allyl Chloride Sludge . . . . . . . . . . . . . . . . . . . . . . 68
Table 4-20. Waste Management Statistics for Allyl Chloride Sludge . . . . . . . . . . . . . . . . . . . . 68
Table 4-21. Waste Characterization Data for Allyl Chloride Sludge . . . . . . . . . . . . . . . . . . . . . 69

Background Document, Version 1 iii July 30, 1999
Table B-1. Analytical Data Summary, Sample by Sample . . . . . . . . . . . . . . . . . . . . . . . . . . . 121
Table C-1. Facilities Providing Chlorinated Aliphatic Listing Split-Sample Data . . . . . . . . . . 176
Table C-2. Split Sample Comparison Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179
Table D-1. Chlorinated Aliphatics Wastewaters, by Management Type and Facility - 1996 Data
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197
Table D-2. Chlorinated Aliphatics Wastewater Treatment Sludges, by Management Type and
Facility - 1996 Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199
Table D-3. Chlorinated Aliphatics Wastewaters, by Management Type and Facility - 1991 Data
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 200
Table D-4. Chlorinated Aliphatics Wastewater Treatment Sludges, by Management Type and
Facility - 1991 Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 202
Table E-1. Summary of Chlorinated Aliphatics Manufacturers . . . . . . . . . . . . . . . . . . . . . . . 205

Background Document, Version 1 iv July 30, 1999
1. INTRODUCTION
1.1 Background
The U.S. Environmental Protection Agency’s (EPA’s) Office of Solid Waste (OSW), as
directed by Congress in the Hazardous and Solid Waste Amendments (HSWA) of 1984 to the
Resource Conservation and Recovery Act (RCRA), has undertaken an investigation of the
chlorinated aliphatics industry. This investigation was mandated by a 1994 consent decree
resulting from litigation brought by the Environmental Defense Fund (EDF). The consent decree
specifically requires listing determinations be made on “wastewaters and wastewater treatment
sludges from the production of the chlorinated aliphatics specified in the F024 listing.”
Under this consent decree, the Agency embarked on a multi-year project to determine
whether these wastewaters and wastewater treatment sludges pose a threat to human health and
the environment, and to develop a basis for making such a determination. This background
document presents the information collected to support the listing determinations.
OSW studied the chlorinated aliphatics industry previously in the early 1980s. This
industry study resulted in several hazardous waste listings, including F024, F025, and numerous K
listings (see Section 1.2). The F024 listing, which covers a variety of process wastes from the
manufacture of chlorinated aliphatics, specifically excludes the two waste streams addressed in
this listing determination: wastewaters and wastewater treatment sludges (see Table 1-1). Spent
catalyst wastes also are specifically excluded from the F024 definition and for a short period of
time the Agency also initiated data collection efforts with respect to spent catalyst wastes.
However, the Agency did not pursue listing determinations for spent catalyst wastes.
For the purposes of the current listing investigation, the Agency defined “chlorinated
aliphatic” as it had previously in the F024 listing. Specifically, a chlorinated aliphatic is defined as
any organic compound characterized by straight-chain, branched-chain, or cyclic hydrocarbons
containing one to five carbons, with varying amounts and locations of chlorine substitution.
Hydrocarbons are organic compounds composed solely of the atoms hydrogen and carbon.
Aliphatics occur where the chemical bonding between carbon atoms are single, double, or triple
covalent bonds (not aromatic bonds). Cyclic aliphatic hydrocarbons included in this class consist
of alkanes, alkenes or alkadienes, and alkynes. For an aliphatic to be chlorinated, the hydrogen
atoms in the “aliphatic hydrocarbon” have been chemically replaced with chlorine atoms, at
different positions and also in multiple positions. It should be noted that while the F024 and F025
definitions are limited to wastes generated from the production of chlorinated aliphatics by free
radical catalyzed processes, the Agency did not limit the current industry study to free radical
catalyzed processes.
Chlorinated aliphatics products and intermediates reported (as of 1996) from facilities
studied as part of this listing investigation include those involved in the manufacture of (CAS
registry numbers are included in parenthesis):

Background Document, Version 1 1 July 30, 1999
C allyl chloride (107-05-1) C 1,2,3-trichloro-3-butene (2431-50-7)
C chloromethane (74-87-3) C 1,3-dichloro-2-butene (926-57-8)
C dichloromethane (75-09-2) C 1,1,2-trichloroethane (79-00-5)
C chloroform (67-66-3) C 1,1,1-trichloroethane (71-55-6)
C carbon tetrachloride (56-23-5) C methallyl chloride (513-37-1)
C chloroprene (126-99-8) C perchloroethylene (127-18-4)
C ethylene dichloride (EDC) (107-06-2) C trichloroethylene (79-01-6)
C trans-1,2-dichloroethylene (156-60-5) C chloroethane (75-00-3)
C 1,3-dichloropropene (542-75-6) C vinylidene chloride (75-35-4)
C vinyl chloride monomer (VCM) (75-01-4) C 3,4-dichloro-1-butene (760-23-6)
C hexachlorocyclopentadiene (77-47-4) C 1,4-dichloro-2-butene (764-41-0)
C 2,3-dichloro-1,3-butadiene (1653-19-6)
As part of the Agency’s current investigation of residuals from chlorinated aliphatics, EPA
conducted engineering site visits at manufacturing facilities to gain an understanding of the
present state of the industry. The Agency collected familiarization samples to obtain data on the
nature of the residuals of concern and to identify potential problems with respect to record
sampling and analysis of the residuals of concern. Concurrently, the Agency developed,
distributed, and evaluated a census survey of the industry. Science Applications International
Corporation (SAIC) (EPA Contract No. 68-W4-0042) assisted EPA/OSW in an engineering
review and subsequent entry of the questionnaire data into the Chlorinated Aliphatics Industry
Studies Database (ISDB).
Due to budget constraints, the Agency suspended activity on the Chlorinated Aliphatics
Listing Determination in late 1993, prior to collecting record samples. The listing determination
process was resumed in May of 1996. Due to this lapse in the study, the Agency reevaluated the
status of the industry via a questionnaire update request (1996 data) and various telephone
conversations with facility contacts. Data from the questionnaire updates were incorporated into
the Chlorinated Aliphatics ISDB. Utilizing the updated data, the Agency revised site selection
and sample locations for the record sampling program and completed record sampling and
analysis by the end of 1997.
1.2 Existing Chlorinated Aliphatics Listings
The Agency previously promulgated a series of listings that apply to the chlorinated
aliphatics industry in previous investigations in the 1980s. These listing are associated both with
general chlorinated aliphatics productions process and with the production of specific chlorinated
aliphatic chemicals. In addition to the hazardous wastes shown in Table 1-1, there are a number
of chlorinated aliphatics chemicals that are listed hazardous wastes when they are discarded, off-
specification, container residues, or spills (U and P list wastes). Table 1-2 presents the Toxicity
Characteristic (TC) hazardous wastes that also are chlorinated aliphatics.
Table 1-1. Existing Chlorinated Aliphatics Listed Hazardous Wastes

Hazardous Listing Description Date of FR
Waste Publication
Listing
F024 Process wastes, including but not limited to, distillation residues, heavy 12/11/89
ends, tars, and reactor cleanout wastes from the production of certain
chlorinated aliphatic hydrocarbons, by free radical catalyzed processes.
These chlorinated aliphatic hydrocarbons are those having carbon chain
lengths ranging from one to and including five, with varying amounts and
positions of chlorine substitution. [This listing does not include wastewaters,
wastewater treatment sludges, spent catalysts, and wastes listed in 40 CFR
261.31 or 261.32.]
F025 Condensed light ends, spent filter and filter aids, and spent desiccant wastes 12/11/89
from the production of certain chlorinated aliphatic hydrocarbons, by free
radical catalyzed processes. These chlorinated aliphatic hydrocarbons are
those having carbon chain lengths ranging from one to and including five,
with varying amounts and positions of chlorine substitution.
K016 Heavy ends or distillation residues from the production of carbon 11/12/80
tetrachloride
K018 Heavy ends from the fractionation column in ethyl chlorine production. 11/12/80
K019 Heavy ends from the distillation of vinyl chloride in vinyl chloride monomer 11/12/80
production
K020 heavy ends from the distillation of vinyl chloride in vinyl chloride monomer 11/12/80
production.
K028 Spent catalyst from the hydrochlorinator reactor in the production of 1,1,1- 11/12/80
trichloroethane.
K029 Waste from the product steam stripper in the production of 1,1,1- 11/12/80
trichloroethane.
K030 Column bottoms of heavy ends from the combined production of 11/12/80
trichloroethylene and perchloroethylene.
K095 Distillation bottoms from the production of 1,1,1-trichloroethane. 11/12/80
K096 Heavy ends from the heavy ends column from the production of 1,1,1- 11/12/80
trichloroethane
Table 1-2. Chlorinated Aliphatic Toxicity Characteristic (TC) Hazardous Wastes
Hazardous Waste Listing Description Date of FR

Listing Publication
D019 Carbon Tetrachloride 3/29/90

Hazardous Waste Listing Description Date of FR
Listing Publication
D022 Chloroform 3/29/90
D028 1,2-Dichloroethane 3/29/90
D029 1,1-Dichloroethylene 3/29/90
D033 Hexachlorobutadiene 3/29/90
D034 Hexachloroethane 3/29/90
D039 Tetrachloroethylene 3/29/90
D040 Trichloroethylene 3/29/90
D043 Vinyl chloride 3/29/90
1.3 Other EPA Regulatory Programs Affecting The Chlorinated Aliphatics Industry
Each of EPA’s major program offices has long-standing regulatory controls that apply to
the chlorinated aliphatics industry. Some of the more significant programs with some relevance to
this listing determination include the following:
C The Clean Air Act’s National Emission Standards for Hazardous Air Pollutants
(NESHAPs) for organic hazardous air pollutants from the synthetic organic chemical
manufacturing industry at 40 CFR Part 63 include the following regulations:
< Subpart F, which applies to any plant which produces ethylene dichloride
(EDC) via oxychlorination, vinyl chloride monomer (VCM) by any
process, or one or more polymers containing any fraction of polymerized
VCM and limits the concentration of vinyl chloride to less than 10 ppm in
process wastewaters and sets standards for emissions of VCM from a
variety of fugitive emission sources.
< Subpart G, which regulates process vents, storage vessels, transfer

operations, and wastewater.
C The Clean Air Act’s National Ambient Air Quality Standards (NAAQS), which prescribe
limits for SOx, CO, particulates, NOx, and ozone.
C The Clean Water Act sets specific effluent guidelines for discharges to surface waters and
POTWs for facilities in the organic chemical, plastic, and synthetic fibers sector, which
includes manufacturers of chlorinated aliphatics.

C The Toxicity Characteristic, particularly for chlorinated aliphatic chemicals (e.g., vinyl
chloride, D043), in combination with existing K and F hazardous waste listings applicable
to chlorinated aliphatics (e.g., F024). There are existing land disposal restrictions (LDR)
for such wastes.
EPA is presently pursuing regulatory approaches which may impact facilities

manufacturing chlorinated aliphatics and generating K173-K175. These programs, obtained from
the April 26, 1999 Unified Agenda (www.gpo.gov), are as follows:
C Land Disposal Restrictions; Potential Revisions for Mercury Listed and Characteristic
Wastes: EPA will soon publish an Advance Notice of Proposed Rulemaking (ANPRM) to
solicit data and comments on treatment data that the Agency has gathered on the
treatment of mercury wastes. The data and information gathered by this ANPRM process
are intended to be used to propose revised treatment standards for some forms of mercury
hazardous wastes in a future rulemaking.
C NESHAP for Chlorine Production: EPA is evaluating emissions from facilities engaged in
the production of chlorine and sodium hydroxide (caustic). Hazardous air pollutants
emitted include chlorine, hydrogen chloride, and mercury. Some of these facilities may be
co-located with chlorinated aliphatics producers.
C NSPS for Synthetic Organic Chemicals Manufacturing Industry: EPA proposed a rule
(September 12, 1994) to develop a new source performance standard to control air
emissions of volatile organic compounds from wastewater treatment operations of the
synthetic chemical manufacturing industry. The rule is scheduled to be finalized in April
2000. Generators of K173 to K175 would likely be subject to this rule, and because it
impacts wastewater treatment operations the quantities of K173 to K175 may be affected
although the direction or magnitude of any change in waste quantities is difficult to
predict.
It is difficult to determine the effect of these regulatory programs on the generation and
management of K173-K175. Some of the regulatory programs underway may, in fact, have little
to no effect on the generation rates and subsequent management of these wastes.

2. INDUSTRY DESCRIPTION
2.1 Chlorinated Aliphatics Industry Overview
2.1.1 Industry Study Profile
In 1992, the U.S. chlorinated aliphatics industry consisted of 27 facilities owned by 20

corporations. However, as a result of questionnaire updates in collected in 1997, the Agency
learned that two chlorinated aliphatic facilities had closed, reducing the number of facilities to 25
and corporations to 19. Chlorinated aliphatics production facilities are located primarily in and
around the petroleum industry along the Gulf Coast. Figure 2-1 illustrates the distribution of
facilities across the country. The majority of these locations are fully integrated petrochemical
processing facilities in which chlorinated aliphatic wastewaters are co-managed with non-
chlorinated aliphatic wastewaters creating a co-mingled wastewater sludge. There are a number
of facilities whose wastewater treatment systems manage only chlorinated aliphatics wastewaters;
for the purpose of this listing determination these treatment systems, and resulting sludges, are
termed “dedicated”.
Nearly 10 million metric tons of chlorinated aliphatics were reported to be produced in

1996 from 23 different chlorinated products and intermediates. (1996 data from the RCRA
Section 3007 questionnaire1). The production capacity for the three largest chlorinated aliphatics
products and intermediates (EDC, VCM, and methyl chloride constitute the great majority of the
total industry-wide production of chlorinated aliphatics) exceeds 20 million metric tons.
(www.chemexpo.com, 1998). For the purposes of this industry study intermediate and product
are defined in relation to the chlorinated aliphatics industry. A chlorinated aliphatic
“intermediate” is a chemical which is produced and consumed on-site in a chlorinated aliphatic
process, a chlorinated aliphatic “product” is a chemical which is either sold or shipped off site or
is consumed on-site in a non-chlorinated aliphatic process (i.e., VCM consumed on-site in the
manufacture of polyvinyl chloride is considered a product, while the EDC consumed during the
manufacture of VCM is considered an intermediate). Of this total, greater than 85% was
EDC/VCM manufactured via the balanced process (see Section 3.1.1). Chlorinated methanes and
chloromethane production volumes accounted for 7% and 3%, respectively. The remaining
volume is produced using nine other processes. Only five of the 25 facilities produce two or more
chlorinated aliphatic products; the four largest facilities manufacture a majority of all chlorinated
aliphatics by volume.
Tables 2.1 and 2.2 provide information on the types of products and manufacturing
processes that are found in the U.S. chlorinated aliphatics industry. These manufacturing
processes are discussed in greater detail in Section 3.
1
Facilities did not always provide production quantities, particularly for captively used intermediates (i.e.,
EDC consumed in the manufacture of VCM), hence this production number is lower than actual 1996 production.

. . .
. . .
. .
.
. . ..
..
Figure 2-1. Geograp
hical Distribution of Chlorinated Aliphatics Manufacturers

Table 2-1. Frequency of Manufacturing Processes within the Chlorinated Aliphatics
Industry (1996 Data)
Processes Generating EDF Consent Production Market Share # of # of
Decree Wastes Quantity Processes Production
(Mtons) Quantities
Not Reported
EDC and/or VCM, balanced process 7,864,697 85.38% 17 2
Chlorinated Methanes 687,735 7.47% 4
Methyl Chloride 270,300 2.93% 3
Perc/Tri/Carbon Tet 0 0.00% 1 1
VCM (based on acetylene) 115,274 1.25% 1
Chloroprene/Chlorinated butenes 108,319 1.18% 2
Methyl chloroform (1,1,1-trichloroethane) 57,280 0.62% 2 1
VDCM (Vinylidene Chloride) 48,398 0.53% 2 1
Trichloroethylene 27,800 0.30% 1
Hexachlorocyclopentadiene 19,902 0.22% 1
Methallyl Chloride 6,909 0.08% 1
Allyl Chloride 5,000 0.05% 1
Total: 9,211,614 Mtons
Process Not Generating EDF Consent Production Market Share # of # of

Decree Wastes Quantity Processes Production
(Mtons) Quantities
Not Reported
Chloroethane 0 0.00% 1 1
trans-1,2-dichloroethylene 0 0.00% 1 1
Allyl Chloride 0 0.00% 1 1
1,3-dichloropropane 0 0.00% 1 1
1,1,2-trichloroethane 0 0.00% 1 1
Perc/Tri/Carbon Tetrachloride 116,014 100.00% 2
Total: 116,014 Mtons

Table 2-2. Products/Processes at Chlorinated Aliphatics Facilities (1996 Data) that
Generate Consent Decree Wastes
Facility Name/Locations Products Manufactured
Borden Chemicals and Plastics; Geismar, LA EDC/VCM (balanced process)
VCM (based on acetylene)
Condea Vista Company; Westlake, LA EDC/VCM (balanced process)
Dow Chemical Company; Freeport, TX Chlorinated Methanes
EDC Only
EDC/VCM (balanced process)
Trichloroethylene
VDCM (Vinylidene Chloride)
Dow Chemical Company; Plaquemine, LA Chlorinated Methanes
EDC/VCM (balanced process)
Dow Corning Corporation; Carrollton, KY Chloromethane
Dow Corning Corporation; Midland, MI Chloromethane
Du Pont-Dow Elastomers LLC; LaPlace, LA Chloroprene
Du Pont-Dow Elastomers LLC.; Louisville, KY Chlorobutadienes
FMC Corporation; Baltimore, MD Methallyl Chloride
Formosa Plastics Corp. USA; Baton Rouge, LA EDC/VCM (balanced process)
Formosa Plastics Corp. USA; Point Comfort, TX EDC/VCM (balanced process)
Ge Electric Corporation; Waterford, NY Chloromethane
Georgia Gulf Corporation; Plaquemine, LA EDC/VCM (balanced process)
Occidental Chemical Corp.; Convent, LA EDC Only
Occidental Chemical Corp.; Deer Park, TX EDC/VCM (balanced process)
Occidental Chemical Corp/Oxymar; Gregory, TX EDC/VCM (balanced process), EDC Only
PPG Industries; Lake Charles, LA EDC/VCM (balanced process), EDC Only
MC (1,1,1-trichloroethane)
Perc/Tri/Carbon Tet
VDCM (Vinylidene Chloride)
Shell Oil Company; Norco, LA Allyl Chloride
The Geon Company; LaPorte, TX EDC/VCM (balanced process)
Velsicol Chemical Corporation; Memphis, TN Hexachlorocyclopentadiene
Vulcan Chemicals Company; Wichita, KS Chlorinated Methanes
Vulcan Materials Company; Geismar, LA Chlorinated Methanes
EDC Only
MC (1,1,1-trichloroethane)
Westlake Monomers Corp.; Calvert City, KY EDC/VCM (balanced process)

2.1.2 Recent Developments
Since completion of the updated industry study for 1996, several developments in the
chlorinated aliphatics industry have occurred. Limited information has become available that
indicates that several facilities have either increased production capacity, others have shut down,
and new facilities have opened. Most of this data was obtained from chemexpo.com.
Please note that recent information for all chlorinated aliphatic products and
manufacturing facilities could not be collected in time for this background document. Only the
available information is presented, and no attempt to integrate the information into the 1996
summary was made.
EDC/VCM
Since completion of the industry study and 1996 update, one new facility has begun
production of EDC and VCM, and several facilities have expanded production capacity of EDC
and VCM. Tables 2-3 and 2-4 present these capacities for EDC and VCM, respectively. PHH
Monomers opened a EDC/VCM production unit in late 1996. (www.chemexpo.com, 1998)
Formosa has plans to add 290 million pounds of EDC at Point Comfort. Georgia Gulf
added 400 million pounds of EDC capacity in 1996 at the Plaquemine site. PHH Monomers is a
joint venture of PPG and Condea Vista. Oxymar is a joint venture of Occidental and Marubeni
Corporation. (www.chemexpo.com, 1998)
Borden is planning on increasing their acetylene-based VCM production capacity by 250

million pounds per year by the end of 1997. Georgia Gulf added 350 million pounds of capacity
in 1996 at the Plaquemine facility. OxyMar completed expansion to increase their capacity to 2.1
billion pounds in July 1997. PHH Monomers (joint venture between PPG and Condea Vista)
opened a 500 million pound unit at Lake Charles in 1996. Shintech is planning on opening a
facility with a production capacity of 500,000 metric tons for VCM. (www.chemexpo.com,
1998)

Table 2-3. EDC Production Capacity
Facility Name EDC Capacity (million lbs/yr)
Borden; Geismar, LA 745
Condea Vista Company; Westlake, LA (formerly Vista Chemical) 1,400
Dow, Freeport, TX 4,500
Dow, Plaquemine, LA 2,300
Formosa, Baton Rouge, LA 525
Formosa, Point Comfort, TX 1,900
Georgia Gulf, Plaquemine, LA 1,760
OxyChem, Deer Park, TX 1,950
OxyChem, Convent, LA 1,500
OxyChem, Ingleside (Gregory), TX 1,500
OxyMar, Ingleside (Gregory), TX 3,000
PHH Monomers, Lake Charles, LA 1,400
PPG, Lake Charles, LA 1,600
Geon, LaPorte, TX 4,000
Vulcan Materials Company; Geismar, LA 500
Westlake Monomers Corp.; Calvert City, KY 1,950
(Source: www.chemexpo.com, 1998)
Table 2-4. VCM Production Capacity

Facility Name VCM Capacity (million lbs/yr)
Borden; Geismar, LA 950
Condea Vista Company; Westlake, LA (formerly Vista Chemical) 850
Dow, Plaquemine, LA 1,500
Dow, Freeport, TX 2,200
Formosa, Baton Rouge, LA 1,455
Formosa, Point Comfort, TX 875
Geon, LaPorte, TX 1,650
Georgia Gulf, Plaquemine, LA 1,600
OxyChem, Deer Park, TX 1,100
OxyMar, Ingleside (Gregory), TX 2,100
PHH Monomers, Lake Charles, LA 1,150
Westlake Monomers Corp.; Calvert City, KY 1,200

Methyl Chloride, Methylene Chloride, Chloroform
LCP Chemicals, Occidental, and Vista (now Condea Vista) closed methyl chloride
facilities with a combined capacity of 175 million pounds during 1991 and 1994. Dow and
Vulcan captively use a significant portion of their methyl chloride production to manufacture
other chloromethanes. GE Plastics and Dow Corning use all their methyl chloride production
captively for silicones manufacture. LCP Chemicals and Occidental Chemical closed facilities
with methylene chloride and chloroform capacities totaling 170 and 116 million pounds per year,
respectively, between 1991 and 1994. Vulcan has expanded production of methyl chloride,
methylene chloride, and chloroform its Geismar and Wichita facilities since 1991.
Table 2-5. Methyl Chloride Production Capacity (million lbs/yr)

Facility Name Methyl Chloride Methylene Chloride Chloroform
Dow, Freeport, TX 55 125 200
Dow, Plaquemine, LA 175 125 200
Dow Corning, Carrolton KY 250
Dow Corning, Midland, MI 50
GE Plastics, Waterford, NY 100
Vulcan, Geismar, LA 90 80 160
Vulcan, Wichita, KS 70 100 160
Perchloroethylene
Most perchloroethylene (tetrachloroethylene) has traditionally be co-produced with

carbon tetrachloride by chlorination of propylene. However with the phase out of CFC-11 and
12, which made up virtually all of carbon tetrachloride’s commercial use, chlorinated solvent
manufacturers have modified their processes to produce perchloroethylene while minimizing or
eliminating carbon tetrachloride. Occidental Chemical and Dow shut down perchloroethylene
facilities with a total capacity of 230 million pounds in the early 1990s, and Vulcan closed a 25-
million pound plant at Wichita in late 1996.
Table 2-6. Perchloroethylene Production Capacity

Facility Name Perchloroethylene Capacity
(million lbs/yr)
Dow, Plaquemine, LA 90
PPG, Lake Charles, LA 125
Vulcan, Geismar, LA 140
Trichloroethylene
Trichloroethylene can be produced by chlorination of ethylene or EDC. Dow is scheduled
to complete an expansion in 1998 to raise capacity and improve efficiency of its trichloroethylene
plant in Freeport, TX. Use of trichloroethylene in fluorocarbon production and as a metal
cleaning and degreasing solvent are increasing. TCE has gained some market share in vapor
degreasing as a result of the phaseout of 1,1,1-trichloroethane for emissive uses. Growth as a
fluorocarbon feedstock has more potential as TCE is a precursor for HFC-134a.
Table 2-7. VCM Production Capacity

Facility Name EDC Capacity (million lbs/yr)
Dow, Freeport, TX 120
PPG, Lake Charles, LA 200
2.2 Industry Study
OSW’s current listing determination for the chlorinated aliphatics industry has been
underway since 1992 and consisted of two major avenues for information collection: field work
and industry survey. As part of the field work component, the Agency conducted engineering site
visits, familiarization sampling, and record sampling. The survey effort included the development,
distribution, and assessment of an extensive industry-wide RCRA Section 3007 survey. Each of
these elements is described further below, reflecting the relative order in which the Agency
conducted these activities over the past 7 years.
2.2.1 Engineering Site Visits
EPA initiated field activities with a series of engineering site visits. The primary purpose
of the site visits was to gather first-hand information about manufacturing processes, as well as
waste generation, management, and characterization data for each of the two consent decree
wastes. In addition, the goals of each engineering site visit included:
1) familiarizing industry with the goals and scope of this listing determination as well as the
general steps that EPA will follow in making a determination,
2) clarifying information provided in the RCRA Section 3007 Questionnaire,
3) acquiring any additional information not supplied in the questionnaire regarding waste
minimization activities, as well as information valuable to supporting risk assessment
determinations, and
4) determining which wastes of interest are generated at the facility, their location, and other
information vital to potentially sampling these wastes.

After considering logistical and budgetary constraints, the Agency selected 16 facilities for
site visits prior to record sampling. These facilities were selected in order to obtain the most
representative sampling of all chlorinated aliphatics processes, and to examine dedicated
wastewater treatment units, when possible. The selected facilities are presented in Table 2-3.
Table 2-8. Engineering Site Visits Conducted
Facility/Location Site Visit Date
Dow Chemical; Freeport, TX 2/23/93
Occidental Chemical; Deer Park, TX 2/24/93
PPG Industries; Lake Charles, LA 2/25/93
Occidental Chemical; Convent, LA 3/16/93
Formosa Plastics; Baton Rouge, LA 3/17/93
Vulcan Chemical; Geismar, LA 3/18/93
Georgia Gulf; Plaquemine, LA 4/6/93
Shell Chemical; Norco, LA 4/7/93
Dupont-Dow Elastomers; LaPlace, LA 4/8/93
The Geon Company (formerly B.F. Goodrich); LaPorte, TX 5/11/93
Borden Chemicals and Plastics; Geismar, LA 5/12/93
Occidental Chemical; Belle, WV 6/8/93
Velsicol Chemical; Memphis, TN 6/9/93
Dow Corning; Carrollton, KY 6/15/93
Dupont-Dow Elastomers; Louisville, KY 6/16/93
FMC Corporation; Baltimore, MD 6/29/93
The Agency developed an engineering site visit report for each of the trips. The site visit reports
include the following elements:
• Purpose of Site Visit

• Regulatory and Legal Basis for a Listing Determination
• Chlorinated Aliphatics Process Chemistry
• Process Descriptions
• Waste Streams and Waste Management Practices
• Familiarization Sampling Activities
• Site Visit Chronology

•
These reports are available in the rulemaking docket.
2.2.2 RCRA Section 3007 Questionnaires
EPA developed an extensive questionnaire under the authority of Section 3007 of RCRA
for distribution to the chlorinated aliphatics manufacturing industry (a blank copy is provided as
Appendix A). The purpose of the RCRA Section 3007 Questionnaire was to gather information
about solid and hazardous waste management practices in the U.S. chlorinated aliphatics
manufacturing industry. The Agency used this information to determine whether certain waste
streams should be managed as hazardous under RCRA and added to the list of hazardous wastes
under 40 CFR 261. The questionnaire included sections requesting information with respect to:
• Corporate and facility information
• Types of chlorinated aliphatic products and chlorinated aliphatic intermediates
manufactured at the facility
• Types of processes at the facility
• Solvent use during the manufacturing process2
• Specific manufacturing processes; as well as residuals generated
• Residuals characterization
• General residual management information
• Specific on-site residual management information
• Source reduction efforts
• Signed certification
EPA distributed the survey in November of 1992 to 57 facilities and/or corporations

identified as potential manufacturers of chlorinated aliphatic chemicals. The Agency extracted
this list of facilities from the most recent information available at the time. Information resources
included, but were not limited to:
• Documents and reports generated from previous listing determinations for the
chlorinated aliphatics industry (F024/F025 and the numerous K listings)
• Toxic Release Inventory (TRI) data
• United States International Trade Commission’s (USITC) Synthetic Organic
Chemicals reports
• SRI’s Directory of Chemical Producers
• Conversations with the Halogenated Solvents Industry Alliance (HSIA) Division
of the Chlorine Institute
• Conversations and telephone calls with industry representatives.
2
Information regarding solvents usage requested to support the concurrent spent solvents industry study.
Of the 57 surveys distributed, industry returned 28 surveys reporting that they had manufactured
chlorinated aliphatics in 1991. These 28 questionnaires belonged to 27 facilities representing 20
companies3.
SAIC engineers reviewed the completed surveys for completeness and entered the data
into a relational data base. SAIC subjected the entries in the data base to a series of quality
assurance reviews to identify inappropriate entries and missing data links. In addition, SAIC
conducted an exhaustive engineering review of each facility’s response, resulting in follow-up
letters and/or telephone calls to facility representatives seeking clarifications, corrections, and
additional data where needed. The responses to these requests for clarification, along with
additional information gathered during engineering site visits and familiarization and record
sampling activities were integrated into the data base.
As noted in Section 1.1, EPA suspended activity on this listing determination project for
two and a half years between the fall of 1993 and spring of 1996. Upon resuming the listing
determination activities in 1996, the Agency initiated a review of data collected prior to the work
stoppage. EPA contacted facility representatives to gather information regarding the current
status of chlorinated aliphatics manufacturing operations. Ultimately, in June of 1997 the Agency
sent requests for updated data (for calendar year 1996) regarding consent decree wastes
generated by each facility. SAIC processed the data received from this request in the same
manner as the original RCRA surveys, and entered into the data base. During the work stoppage,
two chlorinated aliphatics manufacturers ceased operations, leaving a total of 25 chlorinated
aliphatics manufacturing facilities associated with 19 different companies or corporations.
Each of the 25 facilities generated at least one consent decree waste: all 25 facilities
generate wastewater, while 16 reported generation of wastewater treatment sludges.
2.2.3 Familiarization Sampling
As part of the analytical phase of the listing determination, the Agency developed a
Quality Assurance Project Plan (QAPP) for sampling and analysis activities, followed by
collection of 15 “familiarization” samples from three different manufacturing facilities. The
agency collected samples of both consent decree wastes (wastewaters and wastewater treatment
sludges), as well as QA/QC blanks and a single spent catalyst sample. The Agency collected these
samples to assess the effectiveness of the laboratory analytical methods identified in the QAPP for
the analysis of the actual residuals of concern. Table 2-4 provides a summary of the
familiarization samples collected.
3
Occidental Chemical Corp., located in Gregory, TX, submitted two separate questionnaires, one for each
of two manufacturing processes on-site. One of these manufacturing processes is wholly owned by Occidental
while the second is owned by OxyMar, Inc., a joint venture between Occidental and Marubeni.
The results of the familiarization sampling effort essentially confirmed the techniques
identified in the QAPP and indicated that the laboratory generally would be able to achieve
adequate quantitation of target analytes to support the listing determination. The QAPP is
provided in the docket to this rulemaking.
It should be noted that following completion of the familiarization sampling and prior to
initiating record sampling the Agency decided it was necessary to augment the sampling program
outlined in the familiarization QAPP with dioxin/furan analyses for both the aqueous liquid and
solid/sludge matrices. This change is incorporated into the final record sampling QAPP.
Wastewater and wastewater treatment sludge samples collected during the first record sampling
visit were treated as familiarization samples for the dioxin/furan analyses. However, our
contracted laboratories did not encounter analytical difficulties during these analyses and these
samples were deemed appropriate for use as record samples.
Table 2-9. Familiarization Samples Taken

Site Name Sample Sample Sample Name
Date Number
Georgia Gulf 4/6/93 GG-01 Wastewater from EDC phase separator (includes wastewater from
Corporation; EDC caustic treatment and drying stills)
Plaquemine, LA GG-02 Steam stripper effluent bottoms
GG-03 Drainage wastewater from rainwater/pad areas prior to steam
stripping
GG-04 Spent catalyst from oxyhydrochlorination reactor
GG-05 Equipment Blank
GG-06 Dewatered wastewater treatment sludge from pile
Shell Chemical; 4/7/93 SH-01 Equipment Blank
Norco, LA SH-02 Caustic scrubber wastewater from HCl storage tank vent scrubber
SH-03 Wastewater from HCl storage tank vent scrubber
SH-04 Dewatered wastewater treatment sludge from belt press
DuPont-Dow 4/8/93 DP-01 Scrubber wastewater from dichlorobutadiene synthesis
Elastomers; DP-02 Combined wastewater from refining and scrubber wastewater
LaPlace, LA
DP-03 Scrubber wastewater from dichlorobutadiene isomerization unit
DP-04 Brine wastewater from chloroprene production
DP-05 Scrubber wastewater from incinerator

2.2.4 Record Sampling
Prior to the work stoppage in September, 1993, the Agency had finalized a record
sampling strategy and selection of facilities. However, the Agency based this sampling strategy,
in part, on selection of spent catalyst waste streams - wastes that are no longer under
consideration. In addition, 1996 industry data was available for use in the selection strategy. As a
result, the Agency revised the sampling strategy.
Given budgetary constraints and the diversity of the chlorinated aliphatics industry beyond
the EDC/VCM manufacturers, the Agency made every attempt to formulate a record sampling
selection strategy which would ensure representativeness of the industry as a whole. The
remainder of this section describes the rationale employed to identify 1) candidate facilities for
record sampling and 2) individual waste samples.
1) Facility Selection: The Agency evaluated the following issues in selecting chlorinated
aliphatics facilities for record sampling:
a) What type of products are manufactured at the facility? The Agency made every
attempt to make the record sampling program representative of the entire chlorinated
aliphatics manufacturing industry. To ensure sufficient coverage of the industry, each
production process at a facility and its relative prevalence in the industry was taken into
account.
b) Does the facility generate wastes of concern? Even though a facility might
manufacture a chlorinated aliphatic product of interest, the manufacturing process may not
generate either wastewaters or wastewater treatment sludges. The Agency considered all
facilities with production processes generating wastewaters or wastewater treatment
sludges.
c) Does the facility have a dedicated wastewater treatment facility? The Agency
targeted facilities with dedicated wastewater treatment systems over facilities with
treatment systems co-managing non-chlorinated aliphatic wastewaters because these
samples are representative solely of chlorinated aliphatic processes.
d) Has an engineering site visit been conducted at the facility? The Agency gave
priority to facilities that had been selected for a prior engineering site visit. Additional
information regarding sampling locations and process chemistry and engineering was
available for these facilities, simplifying sample collection.
e) What is the geographic location of the facility? Due to budget constraints,

additional consideration was given to facilities conveniently located to those facilities
already chosen for sampling.

2) Sample Selection: In conjunction with the facility selection process, the Agency evaluated
specific sample points. The selection of possible individual waste streams from targeted facilities
was based on the following criteria:
a) Is a wastewater or wastewater treatment sludge generated? The only wastes

streams collected were consent decree wastes (wastewaters and wastewater treatment
sludges).
b) Is the sample location representative of the actual waste entering a risk

management unit? As record sampling data ultimately was used as an input into risk
assessment modeling, it was important to ensure that the samples collected were
representative of the wastes that actually enter waste management units. Ideally,
wastewater samples will be combined influents (referred to as “headworks”) to the
wastewater treatment system, while sludges will be sampled after dewatering operations
prior to on- or offsite management.
c) Is the waste stream generated solely from chlorinated aliphatic processes? Many
wastewaters in the industry are commingled with wastewaters from non-chlorinated
aliphatic manufacturing processes. In these cases, wastewater treatment sludges
generated from the treatment of these commingled wastewaters (also referred to as non-
dedicated headworks) are also considered commingled or non-dedicated. As a result,
collecting wastewater treatment sludges samples from dedicated wastewater treatment
systems was a priority. Similarly, the first choice in sampling wastewaters was at the
headworks of dedicated wastewater treatment systems. At facilities which did not have
dedicated wastewater treatment systems, the Agency collected chlorinated aliphatic
wastewaters prior to commingling (i.e., at point of generation within the chlorinated
aliphatic process), in addition to after commingling (i.e., at the headworks) such that
contaminants may be attributed to chlorinated aliphatics processes, if necessary.
d) Is the waste available for sampling? Certain waste streams are generated only
periodically. For these waste streams, sample collection was not always possible. Facility
personnel were asked when these wastes were expected to be generated, and attempts
were made to sample such wastes.
e) Are there physical limitations to sampling the waste stream? During discussions
with facility personnel and during engineering site visits every effort was made to identify
specific sampling locations for each potential waste stream. Physical limitations such as
piping configurations or extreme temperatures of the waste stream occasionally altered the
point of collection.
The Agency initially targeted additional wastewaters and wastewater treatment sludges.
However, due to additional factors such as process upsets, unscheduled process changes, and

other operational issues, some samples were not collected because it was determined that the
sample would not be representative of wastes generated during “typical” process operations.
Upon completion of the familiarization sampling and analysis effort, the Agency initiated
record sampling and analysis of the two consent decree wastes. The Agency sampled
wastewaters and wastewater treatment sludges from twelve facilities. The Agency collected 52
samples (41 wastewaters and 11 wastewater treatment sludges), in addition to three Trip Blanks
for Volatile Organics and two Field Equipment Rinse Blanks that were analyzed for the same
constituents as the record samples. Additional sample volume was collected for five wastewater
and wastewater treatment sludges to allow the laboratory to perform matrix spike/matrix spike
duplicate (MS/MSD) quality assurance analyses for the aqueous, sludge, and TCLP matrixes. All
record samples were collected during a four month period beginning in April 1997 and ending in
July 1997. A complete sample-by-sample summary of the Agency’s characterization of these
samples is provided in Appendix B and a comparison of this data to split samples voluntarily
submitted by industry is provided in Appendix C.
Table 2-10 presents a summary of the record sampling program and describes the
coverage of the chlorinated aliphatics industry attained by the program. Additionally, Table 2-11
provides a summary of each record sampling facility selected, date of sampling, and descriptions
of the samples collected.
Despite the efforts made, the record sampling program was unable to completely cover the
entire industry. Consent decree waste streams were not sampled from the manufacture of
methallyl chloride (occurs at one location - FMC Corporation, Baltimore, MD). However, this
manufacturing process accounts for less than [0.1%] of the total industry-wide production volume
in 1996. Additionally, samples were not collected from Aldrich Chemical (Milwaukee, WI), as
they manufacture less than 100 lbs, annually, of specialty chlorinated aliphatics compounds.
Neither of these two facilities generate wastewater treatment sludges; wastewaters are discharged
to a POTW following pretreatment at both facilities.

Table 2-10. Representativeness of the Record Sampling Program
Summary of Consent Decree Wastes Sampled

Wastewaters sampled at 12 of 25 facilities generating wastewaters
- headworks sampled at 5 of 7 facilities with dedicated wastewater treatment systems (7 of 9 systems)
- 26% of the industry-wide wastewater quantity was sampled
Wastewater treatment sludges sampled at 8 of 17 facilities generating wastewater treatment sludges
- dedicated sludges sampled at 4 of 7 facilities with dedicated wastewater treatment systems (6 of 9 systems -
one additional system sampled, however no sludge was being generated at time of sampling)
- 85% of the industry-wide sludge quantity was sampled (90% of non-hazardous sludges sampled)
Manufacturing Process Number of wastewater treatment facilities sampled
EDC/VCM 8 of 13 (62%)
Methyl Chloride 1 of 3 (33%)
VCM (using acetylene as a feedstock) 1 of 1 (100%)
Allyl Chloride 1 of 1 (100 %)
Other chlorinated aliphatic processes sampled: 4 of 11 (36%)
- chloroprene
- mixed chlorobutadienes
- hexachlorocyclopentadiene
- incinerator water treatment (EDC/VCM facility)
Industry-wide Total: 15 of 29 (54%)
In addition, the Agency did not collect samples from the following manufacturing
processes, as they were not reported to generate either wastewaters or wastewater treatment
sludges:
• chloroethane (PPG Industries; Lake Charles, LA)

• trans-1,2-dichloroethane (PPG Industries; Lake Charles, LA)
• allyl chloride (Dow Chemical; Freeport, TX)
• 1,3-dichloropropene (Dow Chemical; Freeport, TX)
• 1,1,2-trichloroethane (Dow Chemical; Freeport, TX)
• perchloroethylene/trichloroethylene/carbon tetrachloride (Dow Chemical;
Plaquemine, LA)
• perchloroethylene/trichloroethylene/carbon tetrachloride (Vulcan Materials;
Geismar, LA)

Table 2-11. Samples Collected for Record Analysis4
Site Name Sample Date Sample Sample Name

Number
Occidental; 4/22/97 OG-01 EDC/VCM Wastewater Stripper Bottoms
Gregory, TX5 OG-02 Rock Box Effluent
OG-03 EDC Wastewater Stripper Bottoms to WWTS
OG-04 EDC/VCM WWT Sludge from Filter Press
OG-05 Limestone Neutralization Sludge
OG-06 EDC WWT Sludge from Filter Press
Velsicol; Memphis, 5/20/97 VT-01 Combined Caustic Scrubber Waters (Prior to Carbon
TN Treatment)
VT-02 Caustic Scrubber Water from Incineration
VT-03 Quench Water from Incineration
VT-04 Combined Headworks to Pre-treatment
Dow Corning; 5/21/97 DC-01 WWT Sludge
Carrollton, KY DC-02 Waste HCL from Production Line #1
DC-03 Spent Scrubber Water from Production Line #1
DC-04 Waste HCL from Production Line #2
DC-05 Headworks to the WWTS Following Equalization
DuPont Dow 5/22/97 DK-01 Scrubber Water from DC Process
Elastomers; DK-02 Scrubber Water from TCB Process
Louisville, KY
DK-03 Wastewater from DCD Process
DK-04 Combined WW Headworks to WWT
Borden Chemicals 6/4/97 BG-01 Combined Steam Stripper Bottoms from VCM-E
and Plastics; BG-02 (Not Collected)
Geismar, LA
BG-03 (Not Collected)
BG-04 Dewatered Solids from VCM-E WWT System
BG-05 Rainwater/Padwater from VCM-A
BG-06 Sulfide Treatment Sludge
Vulcan Chemicals; 6/5/97 VG-01 Steam Stripper Bottoms/Effluent
Geismar, LA VG-02 (Not Collected)
VG-03 Steam Stripper Bottoms/Effluent
4
Blanks and MS/MSD samples are not included in this list. Please refer to the QAPP and site-specific
analytical data reports contained in the docket for this rulemaking for discussions of these samples and associated
results.
5
Samples collected from this facility were treated as familiarization samples for dioxin/furan analyses,
however, the dioxin/furan analytical results for these samples ultimately were used with the remainder of the
record samples.
Site Name Sample Date Sample Sample Name
Number
VG-04 (Not Collected)
VG-05 WWT Headworks - Air Stripper Feed
VG-06 WWT System Feed to Neutralization (After Air Stripper)
DuPont Dow 7/10/97 DD-01 (Not Collected)
Elastomers; DD-02 (Not Collected)
LaPlace, LA
DD-03 DCB Isomerization Scrubber Water
DD-04 WW for HCL Recovery
DD-05 CD Brine from Steam Stripping
Occidental 7/11/97 OC-01 EDC Wastewater Stripper Bottoms
Chemical Company;
Convent, LA OC-02 Wastewater Treatment Sludge
PPG; Lake Charles, 7/14/97 PL-01 OHC Stripper Bottoms
LA PL-02 Perc/Tri Stripper Bottoms
PL-03 WTU Stripper Bottoms
PL-04 Metal Hydroxide Sludge
Shell Chemical; 7/15/97 SN-01 HCL Scrubber Water
Norco, LA SN-02 Caustic Scrubber Water
SN-03 Equalization Effluent (Tank 202) - Plant WW
SN-04 Wastewater Prior to Aeration (Tank 251) - Combined
Plant and Refinery WW
SN-05 Wastewater Treatment Sludge
Dow Chemical; 7/17-18/97 DF-01 WW from EDC OHC, Unit V
Freeport,TX DF-02 Biological WWT Sludge
DF-03 WW from EDC OHC, Unit I
DF-04 WW from Trichloroethylene Plant
DF-05 WW Headworks to Biological Treatment, Specialty
DF-06 WW Headworks to Biological Treatment, Chlorohydrin
DF-07 CEP WW from VDCM Production
DF-08 CMP WW from Quench/Stripping
DF-09 CMP WW from Cooling/ Drying/ Neutralization
Geon; 7/21/97 GL-01 WWT Sludge
Laporte, TX GL-02 WW from EDC/VCM, After Stripping

3. MANUFACTURING AND WASTEWATER TREATMENT PROCESS
DESCRIPTIONS
Section 4 presents the Agency’s evaluation on whether wastewaters and wastewater

treatment sludges from chlorinated aliphatics manufacturing processes should be listed as
hazardous wastes. This section presents the manufacturing processes that generate at least one
wastewater and on wastewater treatment systems that generate wastewater treatment sludges.
Process descriptions are presented and points of waste generation are identified for the
manufacturing and waste management operations evaluated in the Chlorinated Aliphatics industry
study. Section 3.1 describes the manufacturing processes and points of waste generation, and
Section 3.2 describes the waste treatment processes generating wastes of concern.
3.1 Chlorinated Aliphatics Manufacturing Processes
The chlorinated aliphatics manufacturing processes have been organized in to the

following waste groups based on the proposed listings:
• Ethylene dichloride/Vinyl Chloride Monomer

Wastewater treatment sludge
• Vinyl Chloride Monomer from Acetylene

Wastewater
• Methyl chloride
• Allyl chloride
• Other (remaining processes)

Wastewaters
Chlorinated methanes
Chloroprene and chlorobutadiene
Methyl chloroform
Vinylidene chloride monomer
Trichloroethylene
Hexachlorocyclopentadiene
Methallyl chloride
Perchloroethylene/Trichloroethylene/Carbon tetrachloride
These groups are based the proposed hazardous waste definitions for K173, K174, and K175.
K173 wastes are wastewaters from generated from the production EDC and VCM, except

wastewaters generated from the production of VCM from acetylene; K174 wastes are wastewater
treatment sludges generated from the production of EDC and VCM; and K175 are wastewater
treatment sludges generated from the production of VCM using mercuric chloride catalyst in an
acetylene-based process. Each of these processes generated at least one wastewater. Additional
chlorinated aliphatic manufacturing processes were identified, however these processes did not
generate any process wastewaters.
3.1.1 Ethylene Dichloride (EDC or 1,2-dichloroethane) and Vinyl Chloride Monomer (VCM
or chloroethene)
Ethylene dichloride and vinyl chloride monomer manufacture are the most common
processes in the chlorinated aliphatics industry. In most cases, EDC is manufactured for captive
use in the production of vinyl chloride monomer. However, at some facilities, EDC is
manufactured as a product for sale or use as an intermediate for other products that include
tetrachloroethylene, 1,1,2-trichloroethane, and trichloroethylene.
Following the manufacture of VCM, many facilities consume VCM on-site as an

intermediate in the manufacture of polyvinyl chloride (PVC). This polymerization reaction is not
within the scope of this listing determination, and was not investigated in the course of this
industry study. Other uses for VCM include the production of 1,1,1-trichloroethane (methyl
chloroform) which is addressed in Section 3.1.7 of this document.
From the industry study, there are 17 EDC and/or VCM manufacturing processes at 15
facilities (12 processes manufacture EDC and VCM, while the remaining five only manufacture
EDC). EDC/VCM manufacture accounts for the vast majority of the chlorinated aliphatics
industry market share (>85% based on reported 1996 production). A summary of the facilities
manufacturing EDC and/or VCM is provided in Table 3-1. Since completion of the industry
study, PHH Monomers in Lake Charles, LA, began producing EDC and VCM in late 1996.
Because this facility came online after completion of the industry study, only limited plant-specific
information on production is included in this background document.

Table 3-1. EDC/VCM Manufacturers
Facility Name Production Process(es)

Borden Chem and Plastic; Geismar, LA EDC/VCM balanced process
Condea Vista Company; Westlake, LA (formerly Vista Chemical) EDC/VCM balanced process
Dow Chemical; Freeport, TX EDC/VCM balanced process
EDC only (direct chlorination)
Dow Chemical; Plaquemine, LA EDC/VCM balanced process
Formosa Plastics Corp; Baton Rouge, LA EDC/VCM balanced process
Formosa Plastics Corp; Point Comfort, TX EDC/VCM balanced process
The Geon Company; LaPorte, TX EDC/VCM balanced process
Georgia Gulf Corporation; Plaquemine, LA EDC/VCM balanced process
Oxy Chemical Corp.; Deer Park, TX EDC/VCM balanced process
Occidental Chemical Corp; Convent, LA EDC only (direct chlorination)
Oxymar; Gregory, TX EDC/VCM balanced process
Occidental Chemical Corp, Gregory, TX EDC only (direct chlorination)
PHH Monomers, Lake Charles, LA* EDC/VCM
PPG Industries, Inc.; Lake Charles, LA EDC/VCM balanced process
EDC only (direct chlorination)
Vulcan Materials Company; Geismar, LA EDC only (oxyhydrochlorination)
Westlake Monomers Corp.; Calvert City, KY EDC/VCM balanced process
* Joint venture between PPG and Condea Vista that began operation in fourth quarter 1996.
3.1.1.1 Process Descriptions
EDC and VCM are commonly manufactured in the chlorinated aliphatic industry by the
“balanced process.” The balanced process consists of three primary reaction steps:
1) direct chlorination of ethylene to produce EDC

2) thermal cracking or pyrolysis of EDC to produce VCM and hydrogen chloride (HCl)
3) oxychlorination of ethylene and HCl from thermal cracking to produce additional EDC
The component reactions and overall reaction are as follows:
Direct Chlorination CH2~CH2 + Cl2 ! ClCH2CH2Cl

EDC Pyrolysis 2ClCH2CH2Cl ! 2CH2 ~CHCl + 2HCl
Oxychlorination CH2~CH2 + 2HCl + ½ O2 ! ClCH2CH2Cl + H2O
Overall Reaction 2CH2~CH2 + Cl2 + ½ O2 ! 2CHCl~CHCl + H2O
Overall, the EDC production between direct chlorination and oxychlorination is evenly split, and
this process results in no net production or consumption of HCl; hence the “balanced process.”
All the HCl produced in the EDC pyrolysis step is used as the feed for oxychlorination. Figure 3-
1 presents a generic process flow diagram for the EDC/VCM balanced process.
Figure 3-1. Generic EDC/VCM Balanced Process
Prior to thermal cracking, the crude EDC undergoes purification. Typically EDC is
manufactured as an intermediate in the subsequent manufacture of VCM. However, in some
cases EDC is manufactured on-site and sent off-site as product or used as an intermediate for
other organic chemicals. In most cases, direct chlorination of EDC is used unless there is a
convenient source of HCl available. In addition, there is one facility in the United States which
manufactures VCM via hydrochlorination of acetylene (this manufacturing process is discussed
separately in Section 3.1.2.)
Addition (Direct) Chlorination to Produce Ethylene Dichloride:
Addition (or direct) chlorination, also referred to as catalytic chlorination, is typically

carried out in the vapor or liquid phase and uses an accelerator such as ferric chloride, aluminum
chloride, antimony pentachloride, or cupric chloride catalyst. The reaction is also influenced by
light, the walls of the reactor vessel, and inhibitors such as oxygen. The typical commercial
reaction involves the chlorination of ethylene at 40-50oC with ferric chloride in a liquid phase
reactor. The following equations illustrate the reactions.
FeCl3 + Cl2 ! (FeCl4 -Cl+)

(FeCl4 -Cl+) + CH2~CH2 ! (CH2ClCH2+FeCl4 -)
(CH2ClCH2+FeCl4 -) ! CH2ClCH2Cl + FeCl3.
Crude EDC product then exits the reactor and travels as an overhead gas to a condenser
system that separates the EDC from noncondensable light ends. After condensation, crude EDC
product is combined with crude EDC from the oxychlorination section (described in the next
section) and forwarded to EDC purification.
Oxychlorination to Produce Ethylene Dichloride
In the presence of oxygen or air and a cupric chloride catalyst, ethylene and hydrogen
chloride react to produce EDC and water. In the balanced process, the source of HCl is typically
generated from the pyrolysis of EDC to VCM. However, in some of the EDC-only
manufacturing processes, HCl may be supplied from other sources. This reaction can take place
in a fluidized or fixed bed reactor and produces ethylene dichloride and water in the following
reaction.
CH2~CH2 + 2HCl + ½ O2
CuCl2
! ClCH2CH2Cl +H2O
250 - 300oC
The product gas stream is sent to a condenser to separate unreacted ethylene from EDC. The
unreacted ethylene is recycled back to the reactor as raw material, and EDC proceeds to a phase
separator, where crude EDC is separated from process wastewater and washed with caustic to
neutralize any residual HCl or chlorine. Crude EDC is then dried to eliminate any water and
forwarded with the crude EDC from the addition chlorination process to purification, before
thermal dehydrochlorination (thermal cracking) to VCM.
Ethylene Dichloride Purification:
Prior to thermal cracking into VCM, crude EDC enters a sequence of distillation columns
to remove light and heavy impurities. The first sequence removes condensable and
noncondensable light impurities. By-product, condensable light impurities are removed as tops
and sent to an on-site industrial furnace while non-condensable light impurities are discharged as
vent (or inerts that must be purged from the process) and sent to a gas incinerator. The bottoms
stream is forwarded to a second distillation sequence to remove heavy impurities.
Noncondensable impurities are again removed from the top and discharged to a gas incinerator.
High-purity EDC is also removed from the top and advanced to the EDC cracking furnaces while
bottoms are refinement. From the Dopp kettle, by-product heavies are sent to the on-site
industrial furnace, and bottoms are discharged for off-site waste management.

Thermal dehydrochlorination of Ethylene Dichloride to Produce Vinyl Chloride Monomer:
Thermal dehydrochlorination of EDC, also known as thermal cracking, produces VCM

and co-product hydrogen chloride.
2ClCH2CH2Cl ! 2CH2~CHCl + 2HCl
This reaction routinely takes place in a cracking furnace operating at temperatures ranging from
425-550°C to convert approximately half the purified EDC into VCM and HCl. The product
stream is sent to a quenching tower and proceeds to an absorber to remove the HCl by-product.
HCl is directed back to the oxychlorination process and used to produce crude EDC. By-product
VCM proceeds, along with unreacted EDC, to a VCM stripper and product still for separation.
Unreacted EDC is added to crude EDC from oxychlorination and recycled to the cracking
furnace. VCM is neutralized with caustic and sent to product storage.
3.1.1.2 Waste Generation and Management
This section focuses on the wastes of concern: wastewaters and wastewater treatment
sludges. The wastewater streams are produced during the EDC/VCM manufacturing process
from the distillation and purification steps, scrubbers used during start-up/shut-down, crude
product washings, phase separation, rainwater, and equipment washdowns. Wastewater
treatment sludges are generated from the treatment these wastewaters.
Wastewaters
Two types of wastewater streams are commonly generated from the manufacture of crude
EDC. The most common process wastewater consists of water generated as a by-product from
the oxychlorination reaction that is separated from the organic EDC phase; this aqueous phase
also includes other process wastewaters from caustic washing of wet crude EDC and removal of
water from wet EDC. The second type of wastewater generated from various ancillary process
activities including: scrubber waters generated during start-up/shut-down operations, drainage
wastewaters generated from equipment washdown, and rainwater in the process areas. These
wastewaters are typically generated intermittently, and are commonly commingled with the other
process wastewaters prior to management.
All EDC/VCM wastewaters are treated in RCRA-exempt tank-based systems or are

directly piped to adjacent privately-owned treatment works (PrOTWs). The majority of the on-
site treatment systems employ biological wastewater treatment. However, some facilities utilize
steam stripping and or carbon treatment only. It should be noted that there are several small
volume, periodically generated wastewaters which were reported to be either incinerated or
landfillled. These wastewaters are typically generated during reactor clean-outs. A small number

of wastewaters were reported to be re-used on-site. At some facilities, acidic wastewaters
generated from HCl removal or recovery from the vent gases are used for pH control in the
wastewater treatment system, or in other areas of the plant. Section 3.2 provides additional
details on wastewater treatment systems in use in the chlorinated aliphatics industry.
Wastewater Treatment Sludges
Wastewater treatment sludges are generated from the treatment EDC/VCM wastewaters.
Sludges are generally dewatered using either plate-and-frame filter presses or belt filter presses
and dewatered sludge is temporarily stored in roll-off containers prior to on-site or off-site
transportation and management. The two most common management methods employed for
EDC/VCM sludges are on- or off-site incineration or landfilling. In all cases, incinerators are
permitted for management of hazardous wastes, while both Subtitle D and Subtitle C landfills are
employed. In addition, one facility (Georgia Gulf; Plaquemine, LA) utilizes an on-site land
treatment unit.
Other Wastes (not within scope of this listing determination)
Other wastes generated by EDC/VCM manufacture include distillation bottoms, spent

catalysts, cleanout wastes, and other residuals. In general, at least one of the following listed
waste codes may apply to these residuals:
F024 process wastes (distillation residues, heavy ends, tars, cleanout) from production
of chlorinated aliphatics
F025 condensed light ends, spent filter/filter aids, and spent desiccants from production
of chlorinated aliphatics
K020 VCM still bottoms
D043 wastes exhibits toxicity characteristic for vinyl chloride
3.1.2 Vinyl Chloride Monomer Using Acetylene as a Raw Material (VCM-A)
Historically, vinyl chloride monomer was first produced commercially in the 1930s from
the reaction of HCl with acetylene. In the 1950s, ethylene became a more plentiful and cheaper
feedstock, and commercial processes were developed to produce vinyl chloride from ethylene and
chlorine. Today, production of vinyl chloride monomer based on acetylene is less common than
the aforementioned EDC/VCM balanced process using ethylene as feedstock. The Agency’s
industry study identified only one chlorinated aliphatics facility (Borden Chemicals and Plastics;
Geismar, LA) using the acetylene-based process. This process represents approximately 1.25% of
the total chlorinated aliphatics industry market share in the U.S., and produces only a small
fraction of total vinyl chloride monomer in comparison to the balanced process. It should be noted

that this facility has recently expanded its VCM production capacity using this process. (See
Section 2.1.2 -- Recent Developments.)
3.1.2.1 Process Description
This process uses acetylene and anhydrous hydrogen chloride as raw materials in a
hydrochlorination reaction to produce vinyl chloride monomer. The basic process chemistry is
shown below.
CH/CH + HCl ! CH2=CHCl
In the Borden process, acetylene from the on-site acetylene plant is first purified to
remove water. Following drying, the acetylene is mixed with anhydrous hydrogen chloride (HCl)
and flows through tubular reactors containing mercuric chloride catalyst. The acetylene and HCl
react to form VCM. There are a series of reactors at the facility consisting of primary, secondary
and vent reactors. The product gas stream from the primary reactors is condensed and sent to a
liquid-vapor phase separator. The vapor from the phase separator is mixed with anhydrous HCl
and unreacted acetylene from downstream purification and fed to the secondary reactors.
Reaction products from the secondary reactors is condensed and phase separated. The vapor
phase is sent to the vent reactor. The vent reactor's effluent is condensed and phase separated.
The liquid phase from each of the phase separators, consisting primarily of VCM, is forwarded to
purification.
The first column in the distillation train is the crude column. In this distillation step, the
overheads consist of unreacted HCl and acetylene and are recycled back to the secondary
reactors. The bottoms from the crude column then are sent to a series of two more distillation
columns to purify VCM product. These units generate product VCM, crude VCM that is sent to
the head of the purification train, and a still bottoms that is sent to a thermal system that recovers
the chlorine value as hydrogen chloric acid.
Wastewaters
There are no wastewaters generated directly from the manufacturing process. The
reported wastewaters are rainwater and other water (from washing and cleaning) collected from
the process area. Due to the presence of mercuric chloride catalyst from catalyst change-outs on
the process pad, the padwater (containing mercury) is treated in a sodium sulfide treatment
system (described in Section 3.2.2.1) prior to being discharged under an NPDES permit, and is
not combined with any other process wastewaters in the plant.

Mercury sulfide wastewater treatment sludge is generated from the treatment of the
process area padwater. This sludge is dewatered prior to temporary storage on-site in a
container. This sludge is managed in an off-site landfill as a nonhazardous waste.
Others (not within the scope of this listing determination)
Additional heavy ends from the VCM purification are incinerated off site as K020
hazardous waste. The stripped chlorinated organic intermediate materials are forwarded to the
thermal units for chlorine recovery has HCl. The mercuric chloride catalyst is replaced as the
reaction process becomes less effective. The spent catalyst has historically been returned to the
manufacturer to utilize and remaining mercury value. Since May, 1994, Borden has actively
pursued an alternative mercury recovery process in the United States.
3.1.3 Methyl Chloride
Manufacture of methyl chloride (chloromethane) is the second most common process in

the chlorinated aliphatics industry. Three facilities manufacture methyl chloride as an intermediate
which is consumed captively in the production of silicones. The remaining facilities manufacture
methyl chloride as the first step in an integrated chlorinated methanes process. Because the
proposed listing addresses methyl chloride only, this section will focus on those facilities and
processes that manufacture methyl chloride only. The manufacture of higher chlorinated
methanes are discussed in more detail in Section 3.1.5.1.
Methyl chloride manufacture accounts for a small percentage of the chlorinated aliphatics
industry market share (<3% based on reported 1996 production). A summary of the methyl
chloride manufacturing facilities is provided in Table 3-2 on the following page.
Table 3-2. Methyl Chloride Manufacturers
Facility Name Production Processes

Dow Corning Corporation; Carrollton, KY Methyl Chloride only
Dow Corning Corporation; Midland, MI Methyl Chloride only
GE Electric Corporation; Waterford, NY Methyl Chloride only
Methyl chloride is commercially manufactured by the hydrochlorination of methanol and

hydrogen chloride. The chemical reaction is shown below.
CH3OH + HCl ! CH3Cl + H20

The hydrochlorination reaction of methanol and HCl takes place in a liquid phase reaction.
The reactor effluent is distilled to remove residual HCl and water as aqueous waste hydrochloric
acid. In some cases, this methanol may be recovered from this stream. The methyl chloride
stream from the distillation unit is dried and forwarded to product storage or sent on for further
conversion to silicones or chlorinated methanes. (See section 3.1.5.1 for discussion on the
manufacture of chlorinated methanes.)
Wastewaters
Three facilities reported generating a total of 371,500 metric tons of wastewaters from the
production of methyl chloride in 1996. Because the product is washed and water is generated as
a by-product of the reaction, acidic wastewaters are generated during product purification. These
wastewaters are sent to onsite wastewater treatment.
Two facilities reported generating a wastewater treatment sludge. However, only a small
percentage of the total wastewater flow to the treatment system can be attributed to methyl
chloride production.
Others (not within the scope of this listing determination)
One facility reported generating a spent sulfuric acid (D001) from product drying which is
sent off-site for recovery. The spent sulfuric acid undergoes thermal destruction that destroys any
organic contaminants and reduces the sulfuric acid to sulfur dioxide (SO2); sulfuric acid then is
regenerated from the SO2.
3.1.4 Allyl Chloride
One allyl chloride (3-chloro-1-propene) manufacturing process (Shell Chemical, Norco,

LA) in the chlorinated aliphatics industry generates wastes within the scope of this listing
determination. A second manufacturing process at Dow Chemical, Freeport, TX does not
generate any wastes of concern.
Propylene is reacted with chlorine in a thermal chlorination reaction in the gas phase. The
reactor product gas is fed to an allyl chloride prefractionator, which separates allyl chloride from
by-product HCl. The crude allyl chloride from the prefractionator is sent to storage, and the HCl
is forwarded to an HCl absorber that generates 37% HCl byproduct. The HCl absorber overhead

is sent to a caustic scrubber. In addition, storage vents from storage of the HCl by-product are
scrubbed with water.
Following crude allyl chloride storage, the allyl chloride enters a three-stage distillation
train. The first column removes light ends, the second column removes heavy ends, and the third
column purifies a portion of the allyl chloride to a sales grade. The allyl chloride from the second
column, which is not purified to sales grade, is fed to a low residence time chlorohydrinator to
produce epichlorohydrin. There is a wastewater that is generated from washing the overhead gas
from the second column to knock out any residual allyl chloride. This wash water, containing
allyl chloride, also is fed to the chlorohydrinator.
Wastewaters
Two wastewater streams are generated from the manufacture of allyl chloride: caustic
scrubber bottoms and HCl scrubber bottoms. These streams are treated in an onsite biological
wastewater treatment system with other process wastewaters.
This facility reported generating a wastewater treatment sludge. However, only a small
fraction (2%) of the total wastewater flow can be attributed to allyl chloride production.
Furthermore, this wastewater treatment system accepts process wastewater from the adjacent
petroleum refining facility.
Others (not within scope of this listing determination)
The following streams are also generated by this process.

- activated alumina from propylene dryer
- molecular sieve from propylene
- regeneration gases from propylene driers
- coke from allyl chloride reactor
- isopropyl alcohol from clean-out of prefractionator
- coke from crude allyl chloride storage (F024)
- light ends (F025) from allyl chloride purification
- heavy ends (F024) from allyl chloride purification
The activated alumina and spent molecular sieve are managed in an off-site nonhazardous
landfill. The regeneration gases are vented to flares. The coke generated from the reactor and
allyl chloride storage are incinerated off-site as hazardous and the heavy and light ends are
incinerated on-site as hazardous. The isopropyl alcohol stream is managed in the on-site
biological wastewater treatment system.

3.1.5 Other Chlorinated Aliphatic Manufacturing Processes
This section describes those chlorinated aliphatics manufacturing processes that generate
process wastewaters. However, these facilities commingle chlorinated aliphatic wastewaters with
other process wastewaters. In many cases, these wastewater streams are commingled with
EDC/VCM wastewaters and would be captured by the proposed listings. Furthermore, in some
cases, the contribution to the total wastewater flow is insignificant and the impact and risks
associated with these streams cannot be determined with any certainty.
3.1.5.1 Chlorinated Methanes
Chlorinated methanes include methyl chloride (chloromethane, CH3Cl), methylene chloride

(dichloromethane, CH2Cl2), chloroform (trichloromethane, CHCl3), and carbon tetrachloride
(tetrachloromethane, CCl4). Facilities producing only chloromethane are discussed in the Section
3.1.3, while facilities producing product carbon tetrachloride via other processes are discussed in
more detail in Section 3.1.5.8. Currently, four facilities produce chlorinated methanes
commercially in the U.S. In general, these facilities use the same processes with minor variations
at each facility.
Table 3-3. Chlorinated Methanes Manufacturers
Facility Name Production Processes

Dow Chemical Company; Freeport, TX Methyl Chloride and other Chlorinated Methanes
Dow Chemical Company; Plaquemine, LA Methyl Chloride and other Chlorinated Methanes
Vulcan Chemicals Company; Geismar, LA Methyl Chloride and other Chlorinated Methanes
Vulcan Materials Company; Wichita, KS Methyl Chloride and other Chlorinated Methanes
Commercial facilities typically use two reaction steps to produce chlorinated methanes.
The first step is methyl chloride (CH3Cl) via hydrochlorination of methanol and hydrogen chloride
and is described in Section 3.1.3. In the second step, methylene chloride (CH2Cl2) and chloroform
(CHCl3) co-products are produced along with crude carbon tetrachloride (CCl4) by-product via
thermal chlorination of methyl chloride. The crude reaction products are cooled in a quench
system, separated in a condensation unit and finally distilled to yield the two individual pure
products. Gaseous hydrogen chloride produced during chlorination is recycled to the
hydrochlorinator from the previous step. Several other processes may be used to produce
chlorinated methanes, however, none of these processes are performed on a large scale. Figure 3-
2 on the following page provides a typical flow diagram for chlorinated methanes production.

Figure 3-2. Chlorinated Methanes Process Flow Diagram
Chlorinated methanes plants reported generating a total of [209,030] MT of wastewaters

in 1996. These wastewaters are typically generated from the methanol hydrochlorination step
where methyl chloride is dried and purified. By-product water from the reaction and subsequent
methyl chloride wash steps generate the bulk of the wastewater. Wastewater treatment sludges
were reported to be generated by these facilities, however chlorinated methanes wastewaters
make up a very small portion of the total wastewater flow. Furthermore, these streams are
commingled with EDC wastewaters, and any wastewater sludge generated would be captured
under the proposed listing.
3.1.5.2 Chloroprene and [Chlorobutadienes]
[Two facilities produce dichlorobutadiene and chlorobutene intermediates which are used
captively to produce chloroprene (2-chloro-1,3-butadiene) and, subsequently, 2,3-dichloro-1,3-
butadiene monomer (DCD).]
In the first process, butadiene, chlorine, and caustic are reacted to form a mixture of 1,4-
dichloro-2-butene (1,4-DCB) and 3,4-dichloro-1-butene (3,4-DCB). The crude DCB mixture is
sent through a series of vacuum distillation units to remove unwanted organics and to separate
and purify the DCB components. 1,4-DCB is sent to an isomerization reactor to convert it to
3,4-DCB. Purified 3,4-DCB is combined with caustic, catalyst, and inhibitors in a series of
reactors to dehydrochlorinate the 3,4-DCB to crude chloroprene. The crude chloroprene is steam
stripped to remove brine that is formed as part of the reaction, and the purified product is sent to
the second process to produce neoprene. This process generates the following wastewaters:

• scrubber wastewaters from DCB production
• brine wastewater from chloroprene stripping unit
• HCl recovery scrubber
The DCB scrubber wastewaters are combined with incinerator scrubber waters and sent to
a clarifier to remove organics. The aqueous phase is neutralized with HCl or NaOH and sent to
underground injection wells as hazardous waste. The organic phase is incinerated onsite as a
hazardous waste. The chloroprene brine is typically sent to a separate clarifier that periodically
generates an organic layer which is sent to the onsite incinerator as hazardous waste. Normally,
the aqueous phase is neutralized with NaOH or HCl, filtered, and disposed in nonhazardous
injection wells. However, it is often combined with the hazardous streams prior to neutralization
to help meet specific gravity requirements of the hazardous waste underground injection well.
Wastewater from the HCl scrubber is reused onsite for its acid value.
[In the second process, chloroprene is hydrochlorinated in to produce 1,3-dichloro-2-

butene (DC). The reaction mixture is sent to a vapor-liquid phase separator to remove excess
HCl gas, and the organic DC layer is decanted from the aqueous catalyst solution. The DC
intermediate is then chlorinated to produce 1,2,3-trichloro-3-butene (TCB). The TCB is purified
by removing residual HCl and excess unreacted DC. In the final step, TCB is dehydrochlorinated
to produce 2,3-dichloro-1,3-butadiene (DCD) monomer. The reactor effluent is steam stripped to
remove brine in the bottoms and the overhead gases are condensed and the organic phase
decanted and sent to distillation to remove unreacted TCB from DCD product. The TCB is
recycled back to the reactor. These processes generate the following wastewaters:
• scrubber wastewaters from DC production

• scrubber wastewaters from TCB production
• brine wastewater from DCD production
• decanter wastewater from DCD production]
All the wastewaters are sent to the onsite wastewater treatment system where the streams
are neutralized with lime and discharged to a POTW for biological treatment. Wastewater
treatment sludges generated from the clarifier are dewatered and managed as hazardous wastes in
an onsite incinerator. These facilities generate at total of [652,357] metric tons of wastewater
from the production of chlorobutadiene and chloroprene.
3.1.5.3 Methyl Chloroform (1,1,1-Trichloroethane)
Methyl chloroform, or 1,1,1-trichloroethane, is commonly produced from (1) thermal or

photochemical chlorination of 1,1-dichloroethane, (2) hydrochlorination of 1,1,2-trichloroethane
produced from 1,1-dichloroethylene, and (3) direct chlorination of ethane. Two facilities
manufacture methyl chloroform in the U.S.. Both facilities use the hydrochlorination of VCM to
intermediate 1,1-dichloroethane; 1,1-dichloroethane is then reacted with chlorine to form methyl

chloroform. However, one facility integrates an EDC/VCM balanced process to manufacture
VCM as a feedstock for methyl chloroform production.
Ethylidene, or 1,1-dichloroethane, is produced commercially from the hydrochlorination

reaction using hydrogen chloride and vinyl chloride. The reactor is followed by a distillation
sequence to remove heavy impurities and unreacted feedstocks from crude 1,1-dichloroethane.
The unreacted feedstocks are recycled back to the reactor, the impurities are disposed as
hazardous wastes, while intermediate 1,1-dichloroethane sent to the chlorination reactors.
1,1-dichloroethane is thermally or photochemically chlorinated to produce methyl

chloroform and HCl . Typical by-products from thermal chlorination include HCl, vinyl chloride,
vinylidene chloride, tetrachloroethanes, and pentachloroethane. The photochlorination process
generates by-products 1,1,2-trichloroethane, tetrachloroethanes, and pentachloroethanes. The
reactor effluent from either process is then forwarded to a distillation sequence to separate by-
products and impurities from the methyl chloroform product.
By-product HCl is removed by stripping and may be recycled to the 1,1-dichloroethane

process for hydrochlorination or other parts of the plant, while other organics and heavy
impurities are separated out in the second sequence. By-product 1,1,2-trichloroethane may be
sold as final product by some facilities is separated in a final sequence from the 1,1,1-
trichloroethane. Along with remaining heavy impurities, it is combined in a distillation sequence
with crude product from the 1,1,2-trichloroethane manufacturing process. Refer to section 3.1.13
for further discussion of typical commercial production using by-product 1,1,2-trichloroethane.
The methyl chloroform is often blended with inhibitors to make a final product.
Wastewaters are generated primarily from neutralizing and drying steps during methyl
chloroform purification. Both facilities reported generated a wastewater treatment sludge,
however only a small percentage of the total wastewater flow to the treatment system can be
attributed to methyl chloroform production. Furthermore, these wastewaters are commingled
with EDC/VCM wastewaters and any wastewater treatment sludges will be captured under the
proposed listing.
3.1.5.4 Vinylidene Chloride Monomer (VDCM) or 1,1-Dichloroethylene

Vinylidene chloride monomer is commercially manufactured by the dehydrochlorination of
1,1,2-trichloroethane. Copolymerization with vinyl chloride, acrylonitrile, and various
alkylacrylates is one of its most important uses. Two facilities reported manufacturing vinylidene
chloride.
1,1,2-Trichloroethane is produced from the direct chlorination of 1,2-dichloroethane

(EDC) with chlorine. The reaction stream is distilled to separate unreacted EDC, by-product
HCl, and 1,1,2-trichloroethane intermediate. No wastewaters are generated during this process.

1,1,2-trichloroethane and an aqueous alkali, such as lime or sodium hydroxide, are
dehydrochlorinated to produce VDCM. By-products from this reaction include water and
calcium or sodium chloride. The reactor effluent is usually rinsed, dried, and distilled to eliminate
water and impurities. The overhead stream from the first distillation sequence consists of crude
VDCM product and must be filtered. Bottoms is forwarded to the second distillation sequence
where unreacted 1,1,2-trichloroethane is separated and recycled to the reactor while polymer
waste is also removed.
Wastewaters are generated from the vinylidene chloride purification step. As noted in the
previous section, water is generated as a by-product of the dehydrochlorination reaction. This
stream is treated onsite in a non-biological treatment system and discharged under NPDES. Both
facilities reported generating a wastewater treatment sludge, however only a small percentage of
the total wastewater flow to the treatment system can be attributed to vinylidene chloride
production. Furthermore, these wastewaters are commingled with EDC/VCM wastewaters and
any wastewater treatment sludges will be captured under the proposed listing.
3.1.5.5 Trichloroethylene
Subsequent to production from acetylene, trichloroethylene is mostly manufactured in the

U.S. from ethylene or 1,2-dichloroethane. With the addition of chlorine, ethylene or
dichloroethane can be chlorinated to produce trichloroethylene and by-product
tetrachloroethylene. In an oxychlorination process, 1,2-dichloroethane also produces
trichloroethylene and by-product tetrachloroethylene (or perchloroethylene). Production of
tetrachloroethylene (or perchloroethylene) is further discussed in section 3.1.12. One facility
(Dow Chemical, Freeport, TX) reported manufacturing trichloroethylene product and
perchloroethylene and HCl byproducts.
Trichloroethylene is produced from direct chlorination and thermal cracking. EDC and
chlorine are reacted and quenched with recycled crude product. The heavies are removed and the
crude products are forwarded to a series of condensers to remove chlorine and HCl. The
condensed organics are sent to an initial distillation step to separate trichloroethylene from the
rest of the stream. The trichloroethylene is dried and forwarded to storage and sales. The
remaining residual organics are sent to a second distillation step were a light and heavy stream are
produced. The light stream is sent to a third distillation to separate crude tetrachloroethylene
from crude trichloroethylene. The crude tetrachloroethylene is shipped offsite to another Dow
facility for finishing and sales, and the crude trichloroethylene is recycled back for purification.
The heavy stream from the second distillation is combined with tetrachloroethane to form a feed
for the cracking furnace. Product from the cracking furnace is recycled back to the second
distillation step.
Wastewaters are generated from the drying and finishing operations, and approximately
8,171 metric tons of wastewater from the generation of trichloroethylene were reported for 1996.
This stream is sent to onsite wastewater treatment in tanks and discharged under NDPES. This

facility reported generating a wastewater treatment sludge, however only a small percentage of
the total wastewater flow to the treatment system can be attributed to trichloroethylene
production.
3.1.5.6 Hexachlorocyclopentadiene
[The Agency’s industry study identified only one domestic manufacturer of

hexachlorocyclopentadiene: Velsicol Chemical in Memphis, TN. Velsicol’s
hexachlorocyclopentadiene production accounts for less than 1% of the total chlorinated
aliphatics industry market share. The facility uses some of the hexachlorocyclopentadiene for
captive use in the production of heptachlor and chlorendic, however, most of the production is for
sale off-site.
Hexachlorocyclopentadiene is produced at Velsicol by reacting cyclopentadiene with

excess chlorine. Cyclopentadiene, chlorine, and a proprietary complexing agent (added to remove
metal impurities during the reaction) are reacted in the liquid phase. Chlorination and
dehydrochlorination occur to form a gaseous mixture of hexachlorocyclopentadiene, chlorine,
cyclopentadiene, HCl, and other reaction products.
From the reactors, unreacted chlorine and by-product HCl sent to an HCl absorber where
chlorine is recovered for raw material. The by-product HCl is sent through carbon treatment to
remove any residual organics, and treated with hydrazine to remove any residual chlorine prior to
storage. The facility also operates a RCRA permitted incinerator to burn the organic process
wastes. The exhaust gases from the incinerator are quenched, sent through an absorber, and
finally scrubbed prior to venting to the atmosphere.
The primary source of wastewaters are from process emission controls from the HCl and
chlorine recovery systems, and from the incinerator emission controls. Rainwater and runoff from
the process areas are also collected and managed. No wastewater treatment sludges are
generated.]
3.1.5.7 Methallyl Chloride
[The Agency’s industry study identified only one domestic manufacturer of methallyl
chloride. Methallyl chloride production accounts for less than 1% of the total chlorinated
aliphatics industry market share, and is used as an intermediate for the production of 7-Hydroxy
(not a chlorinated aliphatic), an intermediate agricultural chemical. 7-Hydroxy is used for
Carbofuran production.
Methallyl chloride (MAC) is manufactured by the direct chlorination of isobutylene. The

reactants are sent to a brine cooler. A side reaction takes place in this cooler that produces tert-
butyl chloride (TBC), an unwanted reaction by-product. Under normal operating conditions, the

reactor effluent is then forwarded to the HCl Plant to recover by-product HCl. This process
typically generates an acidic wastewater that is sent to wastewater treatment.
However, during start-up and other non-typical operations the reactor effluent is not sent
to the HCl recovery process described above, but instead is quenched with water. A decanter
removes acidic wastewater from the crude product and the crude product is forwarded to one of
two crude product storage tanks. When this process is used no by-product HCl is produced.
From storage, crude product is distilled to remove TBC and heavy end impurities from the MAC
product. The heavy ends are incinerated. The purified MAC product, and is forwarded to
storage.
Two wastewaters streams are generated from the MAC process: wastewater from HCl
decanter and HCl scrubber wastewater from the onsite incinerator. In addition, a wastewater
purge from the incinerator’s wet electrostatic precipitator is generated. The incinerator gas is
quenched with water, and the quench effluent water is scrubbed in an HCl scrubber. The
overhead from the HCl scrubber is forwarded to a wet electrostatic precipitator (WESP) to
remove residual particulates in the stack gas. The effluent from the HCl scrubber is neutralized
with caustic to a pH of between 5 and 9.5, before it is forwarded to a final pH adjustment tank in
the wastewater treatment system. The water purge from the WESP is also forwarded to the
wastewater treatment system. The process wastewaters from the MAC process are sent through
carbon adsorption beds prior to combining with other plant wastewaters in an equalization tank.
From the equalization tank, the wastewaters are pH adjusted and discharged to the city sewer
(POTW). No wastewater treatment sludges are generated at this facility.]
3.1.5.8 Tetrachloroethylene/Trichloroethylene/Carbon Tetrachloride
In addition to the process described in Section 3.1.5.1, trichloroethylene,

tetrachloroethylene, and carbon tetrachloroide may be manufactured from a mixed organic
feedstock. One facility utilizes oxychlorination to produce trichloroethylene and
tetrachloroethylene, another uses thermal chlorination to produce tetrachloroethylene and carbon
tetrachloride, and the last facility separates tetrachloroethylene and carbon tetrachloride using
organic streams from various onsite processes as feedstock.
Wastewaters are generated only from the oxychlorination process. The other processes
do not generate wastewaters. Only a small portion of the total wastewater flow to the treatment
system is associated with the tetrachloroethylene/trichloroethylene process, and these wastewaters
are commingled with EDC/VCM wastewaters. Therefore, any wastewater treatment sludges will
be captured under the proposed listing.

3.1.6 Manufacturing Processes That Do Not Generate Wastewater
The following manufacturing processes were identified during the industry study, and
were determined not to generate process wastewaters.
• 1,1,2-Trichloroethane (Vinyl Trichloride)
• Ethyl Chloride
• trans-1,2-dichloroethene
• 1,1-dichloroethane
• 1,1,2,2-Tetrachloroethane
• Pentachloroethane
• beta-Trichloroethane
3.2 Waste Treatment Processes
This section presents a summary of the wastewater treatment systems that manage
wastewaters generated by the chlorinated aliphatics industry. The following sections will focus on
those wastewater systems that manage wastewaters and/or generate sludges included in the
proposed listing definitions.
3.2.1 Biological Wastewater Treatment Systems
In general, most process wastewaters from EDC/VCM manufacturing operations are sent
to a biological wastewater treatment system, along with wastewater from other process units. A
treatment system typically consists of primary clarification or sedimentation to remove solids,
secondary (biological) treatment and clarification for organics destruction, and polishing prior to
discharge under NPDES. The sludges from the primary and/or secondary clarifiers are dewatered
and disposed. Wastewater treatment sludges generated from the treatment of EDC/VCM
wastewaters are included in the proposed listing. Because many facilities commingle process
wastewaters from other chlorinated aliphatics processes, the proposed listing effectively captures
wastewaters from chlorinated aliphatics manufacturing processes other than EDC/VCM.
3.2.2 Non-biological Wastewater Treatment Systems Discharging to NPDES Permitted Sites
In addition to conventional biological treatment, two facilities reported using non-

biological wastewater treatment systems. At the first facility, wastewaters generated from the
production of VCM from acetylene are sent to a sulfide treatment to remove mercury. The
second facility uses a combination of steam stripping, distillation, metals precipitation, and carbon
treatment for its wastewaters.
3.2.2.1 Mercury Sulfide Treatment

The sulfide treatment system manages wastewater (e.g, rainwater, wash water) that
collects on the VCM-A production area. The collected wastewater is fed to a mix tank where
sodium sulfide is added to precipitate mercury as mercury sulfide. Diatomaceous earth is added
to aid in the subsequent dewatering step. Precipitated solids are and DE are dewatered in a plate
and frame press where it is collected for disposal offsite as a nonhazardous waste. The filtered
wastewater is recycled through carbon filters until the mercury concentration is less than 5 ppb
and is discharged under NPDES. This wastewater treatment process is typically run on a batch
basis.
3.2.2.2 Other Nonbiological Treatment
[One facility uses an integrated system of three sets of steam strippers, "waste clarifiers,"
distillation, metals precipitation, and carbon treatment for its wastewaters. Wastewaters from
methyl chloroform and VCM processes are steam stripped and sent to sodium formate
destruction, followed by metals precipitation using sodium hydroxide. Wastewaters from
perchloroethylene, trichloroethylene production are steam stripped and combined with the MC
and VCM wastewaters in the metals precipitation step. The metals precipitation step generates
metal hydroxide solids which are separated and dewatered. Similar to biological treatment,
wastes from other chlorinated aliphatic processes are commingled with the EDC/VCM
wastewaters, therefore these wastewaters are effectively captured by the proposed listing. The
treated wastewater is sent to carbon filter polishing prior to discharge under NPDES.
Other chlorinated aliphatic wastes (e.g., tars, catalyst) are sent to "waste
classifiers/clarifiers" where wastewaters are generated. These streams are sent through multi-
media filters, followed by steam stripping, and then carbon polishing prior to discharge under
NPDES. The recovered organics from the classifiers/clarifiers and the steam strippers are sent to
a bottoms recovery unit.]
3.2.3 Non-Biological Pretreatment Processes Prior to POTW/PrOTW Discharge
In addition, a variety of non-biological pretreatment processes (i.e., steam stripping, pH

adjustment, primary clarification) were reported for facilities discharging to POTWs/PrOTWs.
3.2.4 Underground Injection
Two facilities reported disposing their wastewaters via underground injection.

4. WASTE GROUPINGS
The EPA-EDF consent decree specifically addresses two waste streams requiring listing
determinations: “wastewaters and wastewater treatment sludges from the production of the
chlorinated aliphatics specified in the F024 listing.” However, as a result of the industry study and
record sampling program, the Agency determined that, in certain cases, it was more appropriate
to further sub-divide these two broad waste categories. The Agency is proposing to list as
hazardous three of these waste groupings (see below) and to no-list the remaining three. Section
III.A.1 of the preamble to this proposed rule discusses the rationales utilized to develop the
following six chlorinated aliphatics waste groupings:
• Wastewaters generated from the production of vinyl chloride monomer using mercuric
chloride catalyst in an acetylene-based process (VCM-A Wastewaters, proposed as no-list)
• Wastewaters from the production of chlorinated aliphatic hydrocarbons, except for
wastewaters generated from the production of vinyl chloride monomer using mercuric
chloride catalyst in an acetylene-based process (proposed as K173),
• Wastewater treatment sludges from the production of vinyl chloride monomer using
mercuric chloride catalyst in an acetylene-based process (proposed as K175)
• Wastewater treatment sludges from the production of ethylene dichloride or vinyl chloride
monomer (proposed as K174)
• Wastewater treatment sludges from the production of methyl chloride (proposed as no-list)
• Wastewater treatment sludges from the production of allyl chloride (proposed as no-list)
The following sections, organized by waste grouping, provide a summary of the waste
generation, management, and characterization data collected during the industry study (detailed
summaries of all wastewaters and wastewater treatment sludges, regardless of groupings, are
presented in Appendix D. In addition, discussions are provided which describe how these data
were utilized in the assessment of potential risks from the management of these wastes.
It is important to understand the nature of wastewater treatment systems in the chlorinated

aliphatics industry before reviewing the discussions and data tables in the remainder of this
section. As noted in Section 2, the manufacture of a chlorinated aliphatic product is commonly
only one of several manufacturing operations occurring at a given facility. The other
manufacturing operations may involve different chlorinated aliphatic products, or products
outside the scope of this listing determination. However, individual wastewaters generated from
all of these operations are typically commingled and managed in a common wastewater treatment
system. The combined influent to this wastewater treatment system is referred to as the
“headworks.” In the case where all of the wastewaters contributing to the headworks are
generated from chlorinated aliphatics processes, the headworks is labeled “dedicated.” A non-
dedicated headworks would consist of both chlorinated aliphatics wastewaters and other non-
chlorinated aliphatics wastewaters. The same terminology applies to sludges generated from the
treatment of the headworks waters (i.e., a “dedicated”sludge is one that is generated from the
treatment of a dedicated headworks).
1996 data is presented in each of the tables in Sections 4.1 and 4.2.
4.1 Wastewaters
4.1.1 Proposed No-List: Wastewaters Generated from the Production of Vinyl Chloride
Monomer Using Mercuric Chloride Catalyst in an Acetylene-Based Process (VCM-A
Wastewaters)
This waste grouping defines a single wastewater generated from the VCM-A
manufacturing process utilized by Borden Chemicals and Plastics in Geismar, LA (please refer to
Section 3.1.2 for additional details on this manufacturing process.) This wastewater is segregated
from all other wastewaters generated at the site and treated in a system dedicated to this waste
stream. Waste generation and management statistics for this waste grouping are provided in
Tables 4-1 and 4–2 below.
Table 4-1. Waste Generation Statistics for VCM-A Wastewaters
Facility/Location Headworks % Dedicated Waste Managed as HAZ? Final

Quantity Codes Management
(Mtons)
Borden Chemicals and 22,200 100% -- RCRA-exempt NPDES

Plastics; Geismar, LA tank-based system
Total: 22,200
Table 4-2. Waste Management Statistics for VCM-A Wastewater
Final Management # of # of Streams with Total

Streams Unreported Volumes Volume
(Mtons)
treatment in tanks to NPDES discharge 1 0 22,200
Total 1 0 22,200
Due to the fact that this waste stream is characteristically hazardous for mercury (see
Table 2-6) and is currently managed as a hazardous waste (RCRA-exempt wastewater treatment
system), the Agency believes that no additional regulatory action is required to address the risks
associated with this waste. See the preamble for this proposed rulemaking for additional details
on this no-list decision. As a result, no deterministic or probabilistic risk assessment was
performed.
This wastewater was sampled during the Agency’s sampling program and assigned sample
number BG-05 (see Table 2-6). Table 4-3 provides a summary of the Agency’s analytical
characterization of this sample.

Table 4-3. Waste Characterization Data for VCM-A Wastewaters

4.1.2 Proposed K173: Chlorinated Aliphatics Wastewaters, excluding VCM-A Wastewaters
This waste grouping consists of all wastewaters generated from chlorinated aliphatics
manufacturing with the exception of the wastewater defined in Section 4.1.1. This waste
grouping consists of 75 wastewaters generated by the 23 facilities identified in the Industry Study
and represents the generation of more than 11 million metric tons of wastewater per year. These
wastewaters are commonly commingled with other non-chlorinated aliphatics wastewaters at the
headworks, prior to treatment.
Table 4-4 illustrates the chlorinated aliphatics headworks quantities utilized in the risk
assessment, including the calculated central tendency and high end values used in the risk
assessment. This data does not encompass all of the wastewater headworks which will be
captured by this waste grouping. For the purposes of the risk assessment, non-dedicated
headworks containing less than 50% chlorinated aliphatics wastewaters were not included in the
analysis. Table 4-5 provides a complete waste management statistic summary for all chlorinated
aliphatics wastewaters in this waste grouping. However, it is important to note that Table 4–5
represents a summary of all individual wastewater streams and not combined headworks (see
Appendix D for a complete summary of all individual wastewater streams and associated
headworks).
Table 4-4. Waste Generation Statistics for Chlorinated Aliphatics Headworks used in the Risk Assessment
Facility/Location Headworks % Waste Managed Final

Waste Quantity Dedicated Codes as HAZ? Management
(Mtons)
The Geon Company; LaPorte, TX 962,950 100% -- RCRA- NPDES

exempt
Occidental/OxyMar 417,000 100% -- tank- NPDES
based
PPG Industries; Lake Charles, LA 324,500 100% -- systems NPDES
DuPont-Dow Elastomers; LaPlace, LA 314,770 100% -- No UIC
PPG Industries; Lake Charles, LA 173,600 100% -- RCRA- NPDES

exempt
Occidental/OxyMar 157,500 100% -- tank- NPDES
based
PPG Industries; Lake Charles, LA 127,250 100% -- systems NPDES
Westlake Monomers; Calvert City, KY 98,000 100% -- -- PrOTW
Total: 2,575,570
Central Tendency (average): 321,946
High End (maximum): 962,950

Table 4-5. Waste Management Statistics for Individual Chlorinated Aliphatics Wastewaters
Final Management # of # of Streams with Total Volume

Streams Unreported Volumes (Mtons)
treatment in tank to NPDES discharge 45 4 9,525,343
treatment in tank to POTW discharge 11 0 425,173
treatment in tank to PrOTW discharge 7 0 1,017,734
discharge to UIC on-site 8 0 497,167
drumming and disposal in Subtitle D Landfill 1 0 19
Recovery/re-use/reclamation 3 0 26,120
Total 75 4 11,491,557
For the purposes of assessing risk from the management of this waste stream, the Agency
evaluated the manner in which it is currently managed. Regardless of their final disposition,
chlorinated aliphatics wastewaters are typically stored or treated in tanks. The Agency assessed
the risks associated with treatment in open tanks and found these risks sufficient to support a
hazardous waste listing determination. No further assessments were performed. Although
treatment in surface impoundments was reported for five facilities in 1991, and for two facilities in
1996, the Agency confirmed that no surface impoundments are currently utilized for the
management of chlorinated aliphatic wastewaters. Therefore, a treatment in surface impoundment
scenario was not included in the risk assessment.
Table 4-6. Selection of Risk Assessment Modeling Scenarios: Chlorinated Aliphatics Wastewaters
Management Basis for Consideration in Risk Assessment
treatment in tank to NPDES discharge treatment in an open tank was assessed as it was considered to be a
management practice of concern and is currently in use
treatment in tank to POTW discharge treatment in an open tank was assessed as it was considered to be a
treatment in tank to PrOTW discharge treatment in an open tank was assessed as it was considered to be a
discharge to UIC on-site treatment in an open tank was assessed as it was considered to be a
drumming and disposal in Subtitle D Not included: This management practice was reported for a small
Landfill volume of wastewater generated during reactor clean-out operations
on a periodic basis.
Recovery/re-use/reclamation treatment in an open tank was assessed as it was considered to be a


As a part of the record sampling program, the Agency collected 40 wastewater samples
included in this waste grouping (representing both individual wastewater and headworks
samples). However, for the risk assessment, the Agency only used samples OG-01, OG-03, PL-
01, PL-02, PL-03, and GL-02. Table 4-7 provides a summary of the analytical characterization of
this waste grouping used by the Agency in the risk assessment, including calculated central
tendency and high end concentrations.

Table 4-7. Waste Characterization Data for Chlorinated Aliphatics Wastewaters

Table 4-7. Waste Characterization Data for Chlorinated Aliphatics Wastewaters (cont.)

Table 4-7. Waste Characterization Data for Chlorinated Aliphatics Wastewaters (cont.)

4.2 Wastewater Treatment Sludges
4.2.1 Proposed K174: EDC/VCM Wastewater Treatment Sludges, excluding VCM-A Sludge
This waste grouping consists of all sludges generated from the treatment of EDC/VCM
wastewaters, excluding sludge generated from the treatment of VCM-A wastewater. Please refer
to Sections 3.1.1 and 3.2 for additional details on the manufacture of EDC/VCM and wastewater
treatment systems utilized to manage these wastewaters. This waste grouping consists of 16
wastewater treatment sludges generated by 12 facilities.
As discussed previously, many wastewater treatment systems handling EDC/VCM

wastewaters also handle other chlorinated aliphatic and non-chlorinated aliphatic wastewaters. As
a result, this waste grouping captures a large volume of sludge which would not otherwise be
captured if these wastewater streams were segregated. The total volume of sludge captured by
this waste grouping (based on 1996 data) is 104,561 Mtons. In order to estimate the volume of
EDC/VCM sludge attributable to only the EDC/VCM wastewaters, the Agency calculated
“apportioned” volumes. An apportioned volume it equal to the total sludge volume multiplied by
the percentage of EDC/VCM wastewaters contributing to the total wastewater volume treated6.
The total 1996 apportioned EDC/VCM volume is 6,574 Mtons.
Table 4-8 illustrates the apportioned EDC/VCM sludge quantities utilized in the risk
assessment, including the calculated central tendency and high end values used in the risk
assessment. This table includes all of the EDC/VCM sludges reported to be generated in 1996.
There were two instances where two sludges generated at different facilities were reported to be
disposed at the same facility. As a result, these two pairs of quantities were treated as a single
commingled waste volume in the risk assessment. Each of these four individual waste volumes
are presented in Appendix D. Please note that the italicized quantities (those wastes which are
already hazardous) were not utilized in the risk assessment.
Table 4-9 provides a complete waste management statistic summary for all EDC/VCM
wastewater treatment sludges. Management practices employed for these wastes were limited to
landfilling, incineration, and a single occurrence of land treatment.
The Agency conducted both a deterministic and probabilistic risk assessment for this
waste grouping for two separate management scenarios: land treatment and landfilling. These
two management scenarios represent the only management practices employed for nonhazardous
EDC/VCM sludges, and also are the management practices of most concern. The Agency
decided to use analytical data associated only with dedicated sludge samples to eliminate the
contribution of non-chlorinated aliphatic constituents. As a result, the Agency felt is was
necessary to use apportioned sludge volumes in the risk assessment.
6
In other words, for a facility with a wastewater treatment system generating 100 Mtons of sludge that
treats 75% EDC/VCM wastewaters and 25% non-chlorinated aliphatic wastewater, their apportioned EDC/VCM
sludge volume would be 75 Mtons.
Table 4-8. Waste Generation Statistics for EDC/VCM Sludge
Facility/Location Waste Apportioned Waste Managed as Final Management

Quantity EDC/VCM Waste Codes HAZ?
(Mtons) Quantity (Mtons)1
Dow Chemical; Freeport, TX 72,223 115.5 -- No Subtitle D Landfill
Dow Chemical; Midland, MI 11,100 95.5 -- No Subtitle D Landfill
Dow Chemical; Freeport, TX 5,627 101 -- Yes Subtitle C Landfill
Formosa; Point Comfort, TX 4,5082 1,104.42 -- No Subtitle D Landfill
OxyMar; Gregory, TX -- No Subtitle D Landfill
Borden; Geismar, LA 5,1042 892.32 -- No Subtitle D Landfill
PPG Industries, Lake Charles, LA -- No Subtitle D Landfill
The Geon Company; LaPorte, TX 1,804 1,804 -- No Subtitle D Landfill
Georgia Gulf, Plaquemine, LA 1,750 624.2 -- No Land Treatment
Formosa; Baton Rouge, LA 700 107.3 -- No Subtitle D Landfill
Occidental/Oxymar; Gregory, TX3 625 625 F and K Yes Subtitle C Landfill
Occidental; Convent, LA 500 500 -- No Subtitle D Landfill
Occidental; Deer Park, TX3 442 442 K Yes Subtitle C Landfill
Occidental; Gregory, TX 160 160 -- No Subtitle D Landfill
Condea Vista; Westlake, LA3 11 1.6 D Yes Incinerate as HAZ
7 1.1 D Yes Incinerate as HAZ
Dow Chemical; Freeport, TX3 04 04 D Yes Subtitle C Landfill
Total: 104,561 6,574
Central Tendency (average)3 542.2
High End (maximum)3 1804
Totals used in Risk Assessment3 103,476 4,880

1
Quantities calculated based on the percentage of EDC/VCM wastewaters contributing to the wastewater treatment system
headworks generating the sludge
2
Due to evidence of co-management, individual wastes were treated as a single combined waste quantity for the purposes of the risk
assessment
3
Italics denote wastes not incorporated into the EDC/VCM sludge risk assessment (not used in calculation of central tendency or
high end)
4
This sludge was not generated in 1996.

Table 4-9. Waste Management Statistics for EDC/VCM Sludge

Streams Unreported (Mtons)
Volumes
Storage in pile on-site, on-site land treatment unit 1 0 1,750
Storage in container on-site, Subtitle C incineration (on- 3 1 18

or off-site)
Storage in container on-site, on-site Subtitle D landfill 2 0 83,323
Storage in container on-site, off-site Subtitle D landfill 8 0 12,776
Storage in container on-site, on-site Subtitle C landfill 1 0 5,627
Storage in container on-site, off-site Subtitle C landfill 2 0 1,067
Total 17 1 104,561
Table 4-10. Selection of Risk Assessment Modeling Scenarios: EDC/VCM Sludge
Subtitle D Landfill (on or offsite) management practice currently being used, considered
to be of concern
Subtitle C Landfill (on or offsite) Not evaluated: risks posed by wastewater treatment
sludges managed as hazardous wastes are already
addressed by Subtitle C waste management controls
On-site Land Treatment management practice currently being used; considered

to be of concern
The Agency collected eight (8) samples of EDC/VCM wastewater treatment sludge.
These samples were assigned the following identification numbers: OG-04, OG-05, OG-06, GL-
01, PL-04, OC-02, DF-02, and BG-04 (see Table 2-6). Complete analytical data summaries are
provided for each of these samples in Appendix B. Of these eight, five samples (OG-04, OG-05,
OG-06, GL-01, and OC-02) were of dedicated EDC/VCM wastewater treatment systems,
however one of the five (OG-05) is currently a hazardous waste. The remaining four dedicated
samples were used in the risk assessment, and are presented in Table 4-11 with calculated central
tendency and high end concentrations.

Table 4-11. Waste Characterization Data for EDC/VCM Sludges

Table 4-11. Waste Characterization Data for EDC/VCM Sludges (cont.)

Table 4-11. Waste Characterization Data for EDC/VCM Sludges (cont.)

4.2.2 Proposed K175: VCM-A Wastewater Treatment Sludges
VCM-A wastewater treatment sludge is generated at Borden Chemicals and Plastics in

Geismar, LA from the treatment of the VCM-A wastewater discussed in Section 4.1.1. Please
refer to Sections 3.1.2 and 3.2 for additional details on the manufacture of VCM-A and the
wastewater treatment system utilized to manage these wastewaters. Waste generation and
management statistics for this waste stream are provided in Tables 4-12 and 4-13.
Table 4-12. Waste Generation Statistics for VCM-A Sludge
Facility/Location Waste Quantity Apportioned Waste Managed Final

(Mtons) VCM-A Waste Codes as HAZ? Management
Quantity (Mtons)
Borden Chemicals and 120 120 -- Yes Subtitle C

Plastics; Geismar, LA Landfill
Total: 120 120
Table 4-13. Waste Management Statistics for VCM-A Sludge
Final Management # of Streams # of Streams with Total Volume

Unreported Volumes (Mtons)
Storage in container on-site to 1 0 120

off-site Subtitle C Landfill
Total 1 0 120
The agency did not perform a deterministic or probabilistic risk assessment for this waste.
The results of a groundwater screening analysis in combination with consideration of additional
listing criteria served as the basis for this hazardous waste listing. Please refer to the preamble for
this proposed rulemaking for more details on this decision.
This sludge was sampled during the Agency’s sampling program and assigned sample
number BG-06 (see Table 2-6). Table 4-14 provides a summary of the Agency’s analytical

Table 4-14. Waste Characterization Data for VCM-A Sludge

4.2.3 Proposed No-List: Methyl Chloride Wastewater Treatment Sludges
This waste grouping consists of all sludges generated from the treatment of methyl
chloride wastewaters. Please refer to Sections 3.1.3 and 3.2 for additional details on the
manufacture of methyl chloride and wastewater treatment systems utilized to manage these
wastewaters. There are three methyl chloride sludges generated from two facilities, representing
the generation of [3,219] metric tons of sludge per year.
Table 4-15 illustrates the methyl chloride sludge quantity utilized in the risk assessment,
including the calculated central tendency and high end values used in the risk assessment. This
table includes all of the methyl chloride sludges reported to be generated in 1996. Please note
that the italicized quantities (those wastes which are already hazardous) were not utilized in the
risk assessment.
Table 4-16 provides a complete waste management statistic summary for all methyl
chloride wastewater treatment sludges. Management practices employed for these wastes were
limited to landfilling.
Table 4-15. Waste Generation Statistics for Methyl Chloride Sludge
Facility/Location Waste Quantity Waste Managed as Final

(Mtons) Codes HAZ? Management
Dow Corning; Carrollton, KY 776 -- No Subtitle D

Landfill
GE Electric; Waterford, NY2 [29] F039 Yes Subtitle C

Landfill
[2,414]
Total: [3,219]
Total used in Risk Assessment for 776

both central tendency and high
end:
1
Quantities calculated based on the percentage of methyl chloride wastewaters contributing to the wastewater
treatment system headworks generating the sludge
2
Italics denote wastes not incorporated into the EDC/VCM sludge risk assessment (not used in calculation of
central tendency or high end)

Table 4-16. Waste Management Statistics for Methyl Chloride Sludge

Storage in container on-site, on-site Subtitle D landfill 1 0 776
Storage in container on-site, on-site Subtitle C landfill 2 0 [2,443]
Total 3 0 [3,219]
The Agency conducted both a deterministic and probabilistic risk assessment for this
waste grouping for a single management scenarios: landfilling. This management scenario
represents the only management practice employed for nonhazardous methyl chloride sludges, and
also is the management practices of most concern. The Agency used the only analytical data
available for this waste grouping: a single non-dedicated sludge sample. As a result, the Agency
felt is was necessary to use total (non-apportioned) sludge volume in the risk assessment.
Table 4-17. Selection of Risk Assessment Modeling Scenarios: Methyl Chloride Sludge
On-site Subtitle D Landfill management practice currently being used, considered

to be of concern
On-site Subtitle C Landfill Not evaluated: risks posed by wastewater treatment

sludges managed as hazardous wastes are already
addressed by Subtitle C waste management controls
One of the three sludges presented in Table 4-15 (generated at Dow Corning) was
sampled during the Agency’s sampling program and assigned sample number DC-01 (see Table 2-
6). Table 4-18 provides a summary of the Agency’s analytical characterization of this sample.

Table 4-18. Waste Characterization Data for Methyl Chloride Sludges

4.2.4 Proposed No-List: Allyl Chloride Wastewater Treatment Sludges
This waste grouping consists of all sludges generated from the treatment of allyl chloride
wastewaters. Please refer to Sections 3.1.4 and 3.2 for additional details on the manufacture of
allyl chloride and wastewater treatment systems utilized to manage these wastewaters. There is a
single allyl chloride sludge generated from one facility, representing the generation of 69,000
metric tons of sludge per year.
Table 4-19 illustrates the allyl chloride sludge quantity utilized in the risk assessment,
including the calculated central tendency and high end values used in the risk assessment. This
table includes all of the allyl chloride sludges reported to be generated in 1996. Table 4-20
provides a complete waste management statistic summary for all allyl chloride wastewater
treatment sludges. Management practices employed for these wastes were limited to incineration.
Table 4-19. Waste Generation Statistics for Allyl Chloride Sludge
Facility/Location Waste Apportioned Allyl Waste Codes Managed as Final

Quantity Chloride Waste HAZ? Management
(Mtons) Quantity (Mtons)
Shell Chemical; Norco, 380,0007 1,060 -- No Incineration

LA as NHAZ
Total: 380,0007 1,060
Table 4-20. Waste Management Statistics for Allyl Chloride Sludge

Storage in container on-site, on-site NHAZ incineration 1 0 380,0007
Total 1 0 380,0007
The agency did not perform a deterministic or probabilistic risk assessment for this waste.
The results of an analysis of waste characterization data and the fact that this sludge is generated
from a treatment system which is less than 2% dedicated to chlorinated aliphatic wastewaters, in
combination with consideration of additional listing criteria served as the basis for this no-listing.
Please refer to the preamble for this proposed rulemaking for more details on this decision.
This sludge was sampled during the Agency’s sampling program and assigned sample
number SN-05 (see Table 2-6). Table 4-21 provides a summary of the Agency’s analytical
7
Quantity reported is prior to dewatering (~97% water content).

Table 4-21. Waste Characterization Data for Allyl Chloride Sludge

This page intentionally blank.

Appendix A. RCRA Section 3007 Questionnaire


Appendix B. EPA Record Sampling Analytical Data


Table B-1. Analytical Data Summary, Sample by Sample

Appendix C. Industry Split Sample Comparison with EPA Record Sample Data


Introduction
The U.S. Environmental Protection Agency's Office of Solid Waste (OSW), as directed by
Congress in the Hazardous and Solid Waste Amendments of 1984 (HSWA), is undertaking an
investigation of the Chlorinated Aliphatic Industry to make hazardous waste listing determinations
on industry-specific waste types. This investigation also is mandated by the consent decree
between EPA and the Environmental Defense Fund (EDF). The consent decree specifies that the
Agency must make listing determinations on wastewaters and wastewater treatment sludges
generated from the production of chlorinated aliphatics that are excluded from the F024 and F025
hazardous waste listings. These determinations must be well documented and substantiated to
withstand extensive review within the Agency and by the public.
Upon completion of a familiarization sampling and analysis effort, the Agency initiated
record sampling and analysis of the two consent decree wastes on April 22, 1997, and culminated
with final record sampling event on July 21, 1997. The Agency sampled wastewaters and
wastewater treatment sludges from twelve facilities to obtain 52 samples (41 wastewaters and 11
wastewater treatment sludges). All sampling events were conducted according to guidance
provided by the Quality Assurance Project Plan for Listing/BDAT Determination of Wastes
Generated from the Manufacture of Chlorinated Aliphatic Hydrocarbons (C1 - C5). All facilities
visited during the record sampling phase were entitled to receive duplicate split samples for the
purpose of replicating the Agency’s analytical effort. After the sample results were submitted to
each facility in the form of an analytical data report (ADR), the EPA requested all facilities to
provide, if available, the analytical results of the split-sample analyses. The goal of this effort was
to gain a better understanding of wastestream chemical composition along with the ability to
determine the comparability of the EPA-generated data with Industry split-sample results.
The purpose of this report is to compare facility split-sample analytical data results to the
EPA data obtained from the laboratory analysis of Chlorinated Aliphatics Listing Determination
Samples. There were a total of 52 (41 wastewaters and 11 wastewater treatment sludges)
samples that were collected by SAIC or facility personnel on behalf of the EPA. All EPA samples
were submitted to Agricultural and Priority Pollutants Laboratories, Inc.(APPL) to perform
analyses for volatiles, semivolatiles, metals and general chemistry; and Maxim Technologies, Inc.
to perform dioxin analyses. All sample volumes were also obtained in duplicate for the purpose of
providing the facilities with sample-splits and the possibility of generating a duplicate data set. Of
the twelve facilities sampled, the EPA requested and received split-sample analytical data from six
facilities which represented over 50 percent (23 wastewaters and 5 wastewater treatment sludges)
of the 52 samples collected. Each of these six facilities either contracted the sample analyses to a
commercial laboratory or performed the analysis using an in-house laboratory. A summary of
facilities submitting split-sample data and the associated analytical laboratory performing the
analysis is provided in Table C-1.
Table C-1. Facilities Providing Chlorinated Aliphatic Listing Split-Sample Data
Facility Name Location # Split-Sample Analytical Laboratory

Data Results
Wastewater Sludge
Velsicol Chemical Memphis, TN 4 None Memphis Environmental

Corporation Collected Center
DuPont-Dow Elastomers Louisville, KY 4 None Quanterra Environmental

Collected Services
Borden Chemicals & Geismar, LA 2 2 Gulf Coast Analytical

Plastics Laboratories, Inc
OxyChem Convent, LA 1 1 Gulf Coast Analytical

Laboratories, Inc
Shell Chemical Company Norco, LA 4 1 PACE Analytical and

Triangle Laboratories, Inc
The Dow Chemical Freeport, TX 8 1 In-House Dow Laboratory

Company
Data Evaluation And Comparison
Initially, the facility-reported target constituents for each sample were matched directly to
the corresponding EPA summarized analytical data. Data summary comparison tables for each
facility are included in the Appendix. These comparison tables include only those EPA samples
for which facility results were available. The facility results are presented to the right of the
corresponding EPA data columns and are designated with a “S” after the sample ID to indicate
split-sample. Only those target analytes that were detected in at least one sample for a given
facility are listed according to the analytical method. Constituent concentrations that were present
in one data set but were absent or not detected in the other were designated with a “NR” (not
reported or the analysis was not performed by the laboratory) or if available the associated
laboratory reporting limit.
In an attempt to compare the constituent concentrations reported with the facility split-
sample results to the EPA results, the data comparison tables were used to calculate the Relative
Percent Difference (% RPD) for instances where both values were reported and were greater than
the laboratory reporting limit. The % RPD’s were calculated relative to the EPA constituent
concentration, therefore, a negative % RPD indicates the facility result is greater than the EPA
result, whereas a positive % RPD represents a facility result less than the corresponding EPA
result. Since an established data quality objective for split sample or intralaboratory data
precision was unavailable, a ± 50% RPD was assumed to be reasonable given the interlaboratory
precision guideline established in the Quality Assurance Project Plan (QAPjP) was set at 25%
RPD.
A total of 373 EPA and facility data sets possessed sample concentrations that could be
compared in order to determine the % RPD. For those instances where the % RPD could not be
calculated due to one or both values below the laboratory reporting level or listed as “NR”, a
“NC” was noted to indicate not calculatable. Of the 373 calculated % RPD’s, 257 or 69% were
negative while 116 or 31% were positive. This indicates that approximately two-thirds of the
facility split data were greater than the corresponding EPA concentration. In addition, 37% of the
negative % RPD’s were greater than - 50%, in contrast to 22% of the positive % RPD’s that
were greater than 50%. However, the majority of the % RPD’s greater than 50% were attributed
to sample concentrations that were either at trace levels or qualified as “J” values indicating the
concentrations were below the method detection limit.
Conclusions

Overall, there was good data agreement between the number and types of constituents
reported with the EPA and facility split-sample Chlorinated Aliphatics Listing analytical data. The
facility split-sample data provide additional confirmation and validity to those constituents that
were also reported with the EPA data. Given that data from six separate facility-designated
laboratories were comparted to data from two EPA laboratories, the precision results as measured
by the % RSD are not unreasonable. In addition, there are several possible explanations for
constituent concentration results with poor intralaboratory data agreement. These include
deviations in sample preparation, digestion, extraction , dilution, as well as analyst technique that
may have affected data variability.

Table C-2. Split Sample Comparison Summary

Appendix D. Summary of Waste Generation and Management Practices


Appendix E. Summary of Chlorinated Aliphatics Manufacturers


Table E-1. Summary of Chlorinated Aliphatics Manufacturers


Chlorinated Aliphatics Industry Overview

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United States Office of

Environmental Protection Solid Waste

U.S. ENVIRONMENTAL PROTECTION AGENCY

Science Applications International Corporation

HAZARDOUS WASTE MINIMIZATION AND MANAGEMENT

EPA Contract No. 68-W98-025, WA No. 1-21

3. MANUFACTURING AND WASTEWATER TREATMENT PROCESS DESCRIPTIONS

Chlorinated Aliphatics Listing Determination

Appendix A. RCRA Section 3007 Questionnaire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71

Appendix B. EPA Record Sampling Analytical Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119

Appendix D. Summary of Waste Generation and Management Practices . . . . . . . . . . . . . . . . 195

Appendix E. Summary of Chlorinated Aliphatics Manufacturers . . . . . . . . . . . . . . . . . . . . . . 203

Chlorinated Aliphatics Listing Determination

Chlorinated Aliphatics Listing Determination

Chlorinated Aliphatics Listing Determination

Chlorinated Aliphatics Listing Determination

1.2 Existing Chlorinated Aliphatics Listings

Table 1-1. Existing Chlorinated Aliphatics Listed Hazardous Wastes

Chlorinated Aliphatics Listing Determination

K095 Distillation bottoms from the production of 1,1,1-trichloroethane. 11/12/80

Table 1-2. Chlorinated Aliphatic Toxicity Characteristic (TC) Hazardous Wastes

Hazardous Waste Listing Description Date of FR

D019 Carbon Tetrachloride 3/29/90

Chlorinated Aliphatics Listing Determination

D022 Chloroform 3/29/90

D028 1,2-Dichloroethane 3/29/90

D029 1,1-Dichloroethylene 3/29/90

D033 Hexachlorobutadiene 3/29/90

D034 Hexachloroethane 3/29/90

D039 Tetrachloroethylene 3/29/90

D040 Trichloroethylene 3/29/90

D043 Vinyl chloride 3/29/90

< Subpart G, which regulates process vents, storage vessels, transfer

Chlorinated Aliphatics Listing Determination

EPA is presently pursuing regulatory approaches which may impact facilities

Chlorinated Aliphatics Listing Determination

2.1 Chlorinated Aliphatics Industry Overview

2.1.1 Industry Study Profile

In 1992, the U.S. chlorinated aliphatics industry consisted of 27 facilities owned by 20

Nearly 10 million metric tons of chlorinated aliphatics were reported to be produced in

Chlorinated Aliphatics Listing Determination

Chlorinated Aliphatics Listing Determination

Process Not Generating EDF Consent Production Market Share # of # of

Chlorinated Aliphatics Listing Determination

Chlorinated Aliphatics Listing Determination

Borden is planning on increasing their acetylene-based VCM production capacity by 250

Chlorinated Aliphatics Listing Determination

Table 2-4. VCM Production Capacity

Chlorinated Aliphatics Listing Determination

Table 2-5. Methyl Chloride Production Capacity (million lbs/yr)

Most perchloroethylene (tetrachloroethylene) has traditionally be co-produced with

Table 2-6. Perchloroethylene Production Capacity

Table 2-7. VCM Production Capacity

2.2 Industry Study

2.2.1 Engineering Site Visits

2) clarifying information provided in the RCRA Section 3007 Questionnaire,

Chlorinated Aliphatics Listing Determination

Table 2-8. Engineering Site Visits Conducted

Facility/Location Site Visit Date