?
Need
to
return
call
by
/
at/
between
and
.
Signature:
Project
No.:
0172.01.005.060
DISTRIBUTION
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Project
Name:
304(
m)
OCPSF
Detailed
Study
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
11/
24/
03
Time:
2
p.
m.

Company
Name:
Amendola
Engineering
Contact
Name:
Ellie
Ku
Codding
Phone
No.:
703­
633­
1673
Name:
Gary
Amendola,
440­
808­
6961
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Dioxins
at
OCPSF
Sites
TOPICS
DISCUSSED
AND
ACTION
TAKEN
I
called
Gary
Amendola
to
learn
more
about
the
processes
covered
by
the
OCPSF
Category
that
generate
dioxins,
particularly
in
wastewater.
ERG
had
found
that
most
of
the
companies
that
reported
dioxin
water
releases
in
the
2000
TRI
manufactured
PVC
or
vinyl
chloride
monomer
(
VCM),
and
that
some
had
chlor/
alkali
plants.

Mr.
Amendola
confirmed
that
the
chlor/
alkali
process
is
a
generator
of
dioxins,
as
are
the
ethylene
dichloride
(
EDC)/
VCM
processes.
Most
plants
that
manufacture
VCM
manufacture
EDC
as
well.
The
plants
that
manufacture
both
EDC/
VCM
and
operate
chlor/
alkali
facilities
fall
under
both
the
OCPSF
and
the
Inorganic
Chemicals
ELG
regulations.
PVC
polymerization
is
a
minor
source
of
dioxins.

The
Chlorine
Chemistry
Council
continues
(
CCC)
continues
to
study
dioxins
releases
and
posts
their
findings
on
the
http://
www.
c3.
org
web
site.
They
also
provide
updated
data
to
OPPT.

I
asked
if
dioxins
are
a
1990'
s
problem
or
if
dioxin
releases
continue
today.
He
said
they
are
still
a
problem,
though
progress
has
been
made.
Improved
controls
on
all
sides
include:
segregation
and
treatment
of
contaminated
water
streams,
upgraded
air
emission
controls
to
meet
MACT
standards,
and
proper
containment
and
disposal
of
sludge.
Also,
on
the
P2
side,
several
facilities
recycle
process
tars
rather
than
incinerate
these
materials,
since
incineration
of
these
materials
can
form
dioxin.

I
asked
him
what
other
chemical
processes
he
was
familiar
with
that
were
known
to
generate
dioxins
(
other
than
the
chlor
alkali,
EDC/
VCM,
PVC,
and
TiO
2
processes),
and
he
said
that
without
really
researching
it,
what
came
to
mind
are
perchloroethylene
manufacture
(
when
done
by
a
chlorination
process)
and
the
manufacture
of
pentachlorophenol
(
done
only
in
the
US
by
Vulcan
Chemicals).

He
also
referred
me
to
40
CFR
Part
766
(
TSCA),
which
addresses
product
testing
for
chemical
substances
with
the
potential
to
contain
dioxins.
