AR206065 Response to EPA Information Request
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Grace Specialty Chemicals Co. W. R. Grace & Co.- Conn. 62 Whittemore Avenue Cambridge, Mass. 02140-1692 {617)876-1400 September 12, 1989 Michael Towle, Remediation Enforcement Officer U.S. Environmental Protection Agency PA. CERCLA Remedial Enforcement Section (3HW12) 841 Chestnut Street, 6th Floor Philadelphia, Pennsylvania 19107 - RE: Novak Sanitary Landfill Site Lehigh County, Pennsylvania Dear Mr. Towle: L This letter and the attached response by W.R. Grace & Co. - Conn. (Grace) constitute the response of Grace to the recent "Information Request" sent to the Fogelsville facility of Grace i, by the US EPA. This response includes information that Grace has obtained from its review of documents and from employee interviews and which Grace believes in good faith are responsive to the Information Request. This representation is made with the specific acknowledgement that the comprehensiveness of Grace's response is dependent upon the memories of those interviewed and the current availability of records for the period in question. : : L In providing the information in this response, Grace is making no admission of liability with respect to the Site under any statute or common law. Grace reserves the right to correct any mis impress ions or erroneous assumptions by the EPA of the Agency's consideration of Grace's response and the attached documents. , j • Should you have any questions concerning this response, Grace would be pleased to respond to your inquiries. Very truly yours, Marcia D. Seeler Assistant Environmental Counsel AR206065 Response to EPA Information Request This is a response on behalf of the Peters Fertilizer Products, Fogelstown, Pennsylvania facility (Peters) of W.R. Grace & Co. - Conn, to the US Environmental Protection Agency's supplemental information request regarding the Novak Sanitary Landfill, Lehigh County, Pennsylvania. The information contained in this response reflects a search of documents and discussions with personnel employed at the Fogelsville facility. Information was obtained from the following Peters' employees and/or consultants, Robert Peters, John Peters, David Curtiss, Robert Fager, Michael Pazson, Al Graver, Jim Anderson and Ed Yost. Affidavits have not been submitted, since Grace does not believe that Section 104 (e) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1930 authorizes the agency to require such submittals. EPA Inquiry 1. The types and concentrations (amounts) of hazardous substances contained within raw materials used bv Peters Fertilizer Products and within wastes generated by Peters Fertilizer Products (MSDS or chemical make— up) . Attachment A contains copies of material safety data sheets which are representative of the raw materials used at the Peters' Facility in Al lent own from the early 1970 's until 1978 and at the Fogelsville facility from 1978 until the end of 1984. Although the materials described in the material safety data sheets ara similar to those utilized at the Al lent own and Fogelsville facilities, Grace can not definitively state that the data sheets represent all raw materials present at the facilities during the relevant time frame, or that the manufacturers referenced on the data sheets supplied the raw materials utilized by the facilities during the relevant time, or that all the components of such raw materials have remained tha same ovar time. EPA Inquiry 2. Tha procedures and practices followed today and during tha 1970 's to ensura that packaaina which contained raw materials and hazardous substances were fraa of such materials and substances before dispo.s.aJl.a. The procedures and practices to ensura that packaging which contained raw materials ara frea of such materials bafora disposal remained tha same during tha ralavant time frame. Raw materials wara delivered to tha blending area. Bags of raw material wara slit open with a knife and tha materials fed manually into a rotating mixer. During tha 1970's, the empty packaging was tied into bundles weighing approximately 50 pounds and removed from tha blending area. In tha early 1980's a compactar was installed in tha blending area. Empty packaging was placed into tha compactar and crushed into bundles weighing approximately 500 pounds. AR206066 Raw materials were also received injfiber drums. The lids of the drums were removed and the materials were either fed directly into the rotating mixer, or transferred to other containers prior to being weighed and fed into the process. Although most of the fiber drums in which raw materials were packaged were sold, some were used as waste baskets for office and lunch room waste or as containers for materials distributed to local farmers. The contents of any damaged bags of raw materials or finished products were reworked into the product. Dust collected from the facility's baghouses would also be reworked into the product. Floor sweepings and raw materials which could not be salvaged would be placed in empty fiber drums and distributed to local farmers to fertilize their crops. AR206067 APPENDIX A MATERIAL SAFETY DATA SHEET INTERNATIONAL MINERALS & CHEMICAL CORPORATION 421 E. H«vley Street, Mundeleln, XL 60060 (312) 566-2600. Buciceta Eourt ' (312) 566-2606, After Hour* REC'O DEC 10 1985 SECTION 1. PRODUCT IDENTIFICATION PRODUCT NAME - INDUSTRIAL WHITE MURIATE CAS NO. - 7447-40-7 CHEMICAL FAMILY - Inorganic Sale MOLECULAR WEIGHT - 74.6 CHEMICAL NAME - Fotaaaium Chloride FORMULA - KC1 DOT CLASS - Not Regulated by DOT .' ... *>. i • * '<• : ' SECTION II. COMPOSITION % CAS. NO. irt ^7^. """^^x 99.5 Kin. Na (Maxieua) /§f $£{ 1800 ppca 7647-14-5 Water Inaoluble (Maximum) fj ft* 150 ppm «• Moiature (Maximum) KM ^*Y< .07 7732-18-5 \^V ****if%wM '• ' •• \^^^v ' 3^ - SECTION III. PHYSICAL DATA MELTING POINT - 1423 *F SPECIFIC GRAVITY (H20 - 1) - 1.98 VAPOR PRESSURE, mn Rg - Not Applicable PERCENT VOLATILE - Not Applicable SOLUBILITY IN WATER - Appreciable APPEARANCE AND ODOR - Odorleaa white powder. •---•-•_•«' **• -•• i SECTION IV. FIRE AND EXPLOSION HAZARD .DATA Induatrial White Muriate ia a mm-flaoaable inorganic aalt. It will not aupport combuatioa, and it non-hatardoua. When aubjected to .very high temperatures, it eay releaae aoall 4 amount a of chlorine gaa. _ <^> Mft*, Cod* SECTION V. REACTIVITY DATA , : ' STABILITY - Induatrial White Muriate ia atable under all normal conditiona. INCOMPATABILITY (M*t*riM\m tn tvaid) - Contact vlth hot nitric »eid mav eauae evolution of toxic nitroayl chloride. Contact with other atrong acida may fl produce irritating hydrogen chloride gaaei. HAZARDOUS POLYMERIZATION will not occur. The Information. d«U. and r*comm«ndationt contained rt«r«ir jr« t>«ll«v*d Jo b« •ccur«T«. IMC mafcts no warranty of any kind wh4i«v«r wHn r««o*ct intrtto *M «ti«ci«iw«« •« II«MII««« «««— .-•(.— »fc-~— SECTION VL HEALTH HAZARD DATA Permissible Exposure Limit or TU • Nont established. Ut suggest the OSKA nuisance dust 11«1tW ^ milligrams per cubic mettr of sir for an eight-hour tlne-welgnted-average. 3 EFFECTS OF OYEREXPOSUtt: • ACUTE - Irritation of Wit eyes, skin (especially In cuts or open wounds), nasal passages, and trachea. Swallowing a large amount of potassium chloride My cause Irritation of tht gastrointestinal *> tract, crtmps, diarrhea, tingling of hands or feet, weak pulse, and circulatory.disturbances..£; -LOJG-TERM: Ye».Jilibrftfffentretlons of dust (up to 2000 •Illlgrans per cubic meter) may cause perforation*! CoCI \) 1 •fl'lPr Qi»l)»«Ptm. Long-ten exposure to high concentrations could caust chronic cough and $1 •BlTdoroncnltls. There Is no evidence of permanent lung dinage due to long-ten exposure to •3| potassium chloride dust. TOXICIH DATA: Oral, rat • 1050:3020 mg/kg ' >| FIRST AID: Eyes - Flush thoroughly with water. Including under the eyelids. Set a physician If discomfort or Irritation persists. * Skin - Wash with water. \ Inhalation - Remove to fresh air. Set medical attention If discomfort persists. T Ingestlon - Give large amounts of water and then cause vomiting. Set a physician as soon t as possible If a large amount of potasslua chloride 1s swallowed. f SECTION Vtl. SPILL. LEAK. AND DISPOSAL INFORMATION STEPS TO BE TAKEN IH CASE MATERIAL IS RELEASED OR SPILLEDi v, If uncontamlnated, sweep up or collect, and reuse as product. If contaminated with other materials, collect in suitable containers. WASTE DISPOSAL METHOD -Can generally be disposed of by burial in an approved land .3} disposal facility, in accordance with applicable federal, state, and local regulations. Depending upon type and extent of contamination, if any, other disposal methods may be required by environmental regulatory agencies. SECTION VIII. SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION! If dust concentrations exceed recommended Permissible Exposure Limits, use HIOSR-approved dust respirators, with approval TC-21C-xxx, until feasible engineering controls are completed. VENTILATIONi Local exhaust or other ventilation that will reduce dust concentration, to less than Permissible Exposure Limits is recommended. EYE PROTECTION! If high dust concentrations exist, tight-fitting goggles are recommended to reduce dust exposure to the eyes. OTHER PROTECTIVE EQUIPMENT i Optional. SECTION IX. SPECIAL PRECAUTIONS Store in a dry location to avoid loss of product by solution in water, and to avoid subsequent caking, y «*»*» Hay 2, 1984 Richard Culllckaon, ClU Manager, Induatrial Hygiene MATERIAL SAFETY DATA SHEET ' ~¥'<•'•' "'•- ; . ' ''" '"-'::i." -- . * ' INTERNATIONAL MINERALS & CHEMICAL CORPORATION 421 E. Ravley