RUNTON& WILLIAMS lllllllllllllllllllllllllllllllllllllllll SDMS DocID 2157757 HUNTON & WILLIAMS LLP RIVERFRONT PLAZA, EAST TOWER 95 i EAST BYRD STREET RICHMOND, VIRGINIA 23219-4074 TEL FAX 804 • 788 • 8200 804 - 788 - 82)8 August 31, 2012 Via Overnight Delivery DAN J. JORDANGER DIRECT DIAL: 804 • 788 • 8609 EMAIL: ([email protected]FILE NO: 75734.000002 Robin Eiseman, Esq. Office of Regional Counsel (3RC41) U.S. Environmental Protection Agency Region 3 * 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 Re: Arrowhead Plating Site, Montross, Virginia Dear Ms. Eiseman: On behalf of the O'Gara Group ("O'Gara"), I am writing to respond to certain matters addressed in the July 31, 2012 letter from Ronnie M. Davis of EPA to Richard Herbst of O'Gara concerning the Arrowhead Plating Superfund Site in Montross, Virginia (the "Site"). I am enclosing with this letter a work plan prepared for O'Gara by ECS Mid-Atlantic, LLC ("ECS"). That document addresses tasks that O'Gara intends to undertake to fulfill its obligations as a bona fide prospective purchaser ("BFPP") of the Site. This letter addresses the legal obligations of O'Gara and certain statements in Mr. Davis' letter concerning O'Gara's status as a BFPP. Mr. Davis' letter correctly cites the relevant statutory provision when it notes "that preventing or limiting human exposure to hazardous substances is a part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) § 101(40)(B)(IIl), 42 U.S.C. 9601(40)(B)(ffl) 'reasonable steps' requirements for BFPP status." Such reasonable^ steps are part of the duty to exercise "appropriate care with respect to hazardous substances" found at the Site. O'Gara wishes to emphasize, however, that it already has established with the Virginia Department of Environmental Quality ("DEQ") that it qualifies as a BFPP. O'Gara acquired the Site as a Brownfields purchaser and is putting the Site to a beneficial re- use. O'Gara does not have CERCLA liability at the Site, however. Furthermore, O'Gara's exercise of appropriate care must be viewed in light of the failure by others to address adequately the hazardous substances that EPA has acknowledged, in its two most recent five year review reports, to be present under and in the vicinity of the Manufacturing Building. ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES MCLEAN MIAMS NEWYORK NORFOLK RALEIGH RICHMOND SAN FRANCISCO TOKYO WASHINGTON www.huntpn.com AR100044
HUNTON & WILLIAMS LLP RIVERFRONT PLAZA, EAST TOWER 95 i EAST BYRD STREET RICHMOND, VIRGINIA 23219-4074
TEL FAX
804 • 788 • 8200 804 - 788 - 82)8
August 31, 2012
Via Overnight Delivery
DAN J. JORDANGER DIRECT DIAL: 804 • 788 • 8609 EMAIL: ([email protected]
FILE NO: 75734.000002
Robin Eiseman, Esq. Office of Regional Counsel (3RC41) U.S. Environmental Protection Agency Region 3 * 1650 Arch Street Philadelphia, Pennsylvania 19103-2029
Re: Arrowhead Plating Site, Montross, Virginia
Dear Ms. Eiseman:
On behalf of the O'Gara Group ("O'Gara"), I am writing to respond to certain matters addressed in the July 31, 2012 letter from Ronnie M. Davis of EPA to Richard Herbst of O'Gara concerning the Arrowhead Plating Superfund Site in Montross, Virginia (the "Site"). I am enclosing with this letter a work plan prepared for O'Gara by ECS Mid-Atlantic, LLC ("ECS"). That document addresses tasks that O'Gara intends to undertake to fulfill its obligations as a bona fide prospective purchaser ("BFPP") of the Site. This letter addresses the legal obligations of O'Gara and certain statements in Mr. Davis' letter concerning O'Gara's status as a BFPP.
Mr. Davis' letter correctly cites the relevant statutory provision when it notes "that preventing or limiting human exposure to hazardous substances is a part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) § 101(40)(B)(IIl), 42 U.S.C. 9601(40)(B)(ffl) 'reasonable steps' requirements for BFPP status." Such reasonable steps are part of the duty to exercise "appropriate care with respect to hazardous substances" found at the Site. O'Gara wishes to emphasize, however, that it already has established with the Virginia Department of Environmental Quality ("DEQ") that it qualifies as a BFPP. O'Gara acquired the Site as a Brownfields purchaser and is putting the Site to a beneficial reuse. O'Gara does not have CERCLA liability at the Site, however. Furthermore, O'Gara's exercise of appropriate care must be viewed in light of the failure by others to address adequately the hazardous substances that EPA has acknowledged, in its two most recent five year review reports, to be present under and in the vicinity of the Manufacturing Building.
ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES M C L E A N MIAMS N E W Y O R K N O R F O L K R A L E I G H RICHMOND SAN FRANCISCO T O K Y O WASHINGTON
www.huntpn.com
AR100044
HUNTON& WILLIAMS
Robin Eiseman, Esq. August 31, 2012 Page 2
EPA's letter reveals a misunderstanding of steps that O'Gara has taken and intends to take with respect to hazardous substances under and in the vicinity of the Manufacturing Building. Contrary to EPA's statements, O'Gara already has indicated, through the ECS letter of June 13, 2012, that it is continuing to investigate contaminant levels in the Manufacturing Building and the potential risks that they may present to employees and visitors in the building. The work plan submitted to EPA by ECS today sets out in additional detail the appropriate care measures that O'Gara intends to exercise at the property. The tasks set forth in the ECS work plan constitute reasonable steps to prevent or limit exposure to hazardous substances on the property. The goal of those tasks is to protect employees and visitors through the collection of additional chemical data, analysis of potential risk, and identification of appropriate measures to mitigate any unacceptable risk. These reasonable steps will be taken to prevent or limit unacceptable exposure until EPA or a liable party implements permanent measures to address the hazardous substances that remain on the property.
As,EPA has acknowledged, the agency should perform an RI/FS - or at least a site investigation, engineering evaluation and cost analysis - before identifying measures required to mitigate unacceptable risks presented by exposure to hazardous substances at the property. At this time, however, EPA has insufficient data addressing current conditions to perform an evaluation of contamination in the Manufacturing Building, to assess the risks that contamination may present, to identify appropriate alternatives to mitigate such risks, or to designate any particular measure as necessary to prevent or limit human exposure to . hazardous substances.
In conclusion, as a BFPP of the property, O'Gara will continue to fulfill its obligations to exercise appropriate care by taking reasonable steps to prevent or limit human exposure to previously released hazardous substances. Specifically, O'Gara intends to implement the tasks in the work plan submitted today by ECS. O'Gara will collect up-to-date data and perform an assessment of the risks presented by hazardous substances present on the property. Based on that assessment and on other information, O'Gara will determine appropriate care measures suitable for the current and anticipated uses of the Manufacturing Building. O'Gara also will continue to keep EPA and DEQ informed of its findings and any plans for further activities on the property.
Please do not hesitate to contact me if you want additional information on the matters addressed in this letter.
AR100045
HUNTCM& WIIAMS
Robin Eiseman, Esq, August 31, 2012 Page 3
Yours truly,
Dan J. Jordanger
Enclosure cc: Mr. Ronnie Davis (via overnight delivery w/enclosure)
Mr. Thomas Modena (via U.S. mail w/enclosure) Mr. Richard Herbst (via e-mail w/out enclosure) Demian Wincele, C.P.G. (via e-mail w/6ut enclosure)
!. 1
AR100046
WORK PLAN FOR INDOOR AIR SAMPLING O'GARA TRAINING AND SERVICES
ARROWHEAD PLATING SUPERFUND SITE 18047 KINGS HIGHWAY MONTROSS, VIRGINIA
ECS PROJECT NO. 19321
FOR
O'GARA TRAINING AND SERVICES, LLC
AUGUST 31, 2012
AR100047
E C S M1P-ATLA.NT1C, L L C ' . "Setting the Standard for Service'
k GeotfeGhnicai • Construcfton Materials • Environmental • Facilities
August 31,2012
Mr. Richard Herbst Facility Officer O'Gara Training and Services, LLC 18047 Kings Highway Montross, Virginia 22520
ECS Project No. 19321
. Reference: Work Plan for Indoor Air Sampling, O'Gara Training and Services, Arrowhead Plating Superfund Site, 18047 Kings Highway, Montross, Virginia.
Dear Mr. Herbst:
ECS Mid-Atlantic, LLC (ECS) has prepared this Work Plan to describe indoor air sampling procedures for volatile organic compounds (VOCs) from within the former Manufacturing Building at the Arrowhead Superfund Site in Montross, Virginia. This Work Plan has been prepared in response to a letter dated July 31, 2012 from the U.S. Environmental Protection Agency, requesting that the O'Gara Group perform additional work to prevent or limit human exposure to hazardous substances at O'Gara's facility.
Respectfully submitted,
ECS MID-ATLANTIC, LLC
Staff Project Manager
Demi&rf.E. Wincele, C.P.G. Senior Project Manager
l:\Environmental\RPT\19000\19321 0'Gara\Reports\lndoor Air Sampling Work Plan\Text\19321 Work Plan 8-31-12 rev1.doc
rftes"D. Sdccop, C.P.G. Subsidiary Director of Environmental Services
WORK PLAN FOR INDOOR AIR SAMPLING ARROWHEAD PLATING SUPERFUND SITE
18047 KINGS HIGHWAY MONTROSS, VIRGINIA
ECS PROJECT 19321
TABLE OF CONTENTS
SECTION
1.0 PROJECT BACKGROUND
2.0 OBJECTIVES
3.0 METHODS
4.0 REPORTING
5.0 SIX MONTH TIMELINE
List of Tables
Table 1: Site Survey PID Results
List of Figures
Figure 1 - Planned Indoor Air Sampling Locations
Appendices
Appendix I - TO-15 Laboratory Detection Limits Appendix II - Centek Laboratory Certification
AR100049
List of Acronyms
ACGIH American Conference of Governmental Industrial Hygienists ATSDR Agency for Toxic Substances and Disease Registry BFPP Bona Fide Prospective Purchaser CIH Certified Industrial Hygienist COPC Contaminants of Potential Concern CPG Certified Professional Geologist ECS Engineering Consulting Services Mid-Atlantic, LLC EPA Environmental Protection Agency HASP Health and Safety Plan ug/m3 Micrograms per cubic meter OSHA Occupational Safety and Health Administration PEL Permissible Exposure Limit PID Photoionization Detector ppmv Parts per million by volume PRG Preliminary Remedial Goal RAO Remedial Action Objectives RSLs Regional Screening Levels SAP Sampling and Analysis Plan SSDS Sub-Slab Depressurization System STEL Short-term exposure limit SVOC Semi-Volatile Organic Compound TCE Trichloroethylene TGP Technical Guidance Procedure TWA Time-weighted average VDEQ Virginia Department of Environmental Quality VOC Volatile Organic Compound
AR100050
1.0 PROJECT BACKGROUND
The EPA collected indoor air and sub-slab vapor samples at the site in February and July of 2011 as part of the on-going effort to address soil and groundwater contamination that occurred prior to O'Gara's acquisition of the property. The sampling results were screened to determine whether there is an unacceptable risk to workers inside the building. The results of the screening of the February data found that the concentrations of VOCs within the building were, with only one exception, at or below EPA's acceptable levels. Concentrations in the warehouse area resulted in a Hazard Index of 4 (above EPA's goal of 1) and a cancer risk of 7x10"5 (just within EPA's target range). For the office-area workers, the risk was at the upper end of EPA's acceptable risk range. According to the EPA's summary of the screening, the risk is due largely to trichloroethylene (TCE), which was detected at concentrations up to 20 micrograms per cubic meter (ug/m3), which is equivalent to 0.0037 parts per million by volume (ppmv) in the building and up to 10 ug/m3 (0.0019 ppmv) in the office space. The reported concentrations are well below the Occupational Safety and Health Administration's (OSHA) Permissible Exposure Limit (PEL) of 100 ppm as a time-weighted average (TWA) for TCE. Similarly, the American Conference of Governmental Industrial Hygienists (ACGIH) recommends an 8-hour TWA of 50 ppm and a short-term exposure limit (STEL) of 100 ppm.
In accordance with the terms of the bona fide prospective purchaser (BFPP) status O'Gara received from the Virginia Department of Environmental Quality (VDEQ) in August 2010, O'Gara must take reasonable steps and exercise "appropriate care" with respect to the hazardous substances at the property. The limited concentrations of VOCs identified in EPA's indoor air samples suggest that contaminants related to activities at the former Arrowhead plant are present in the indoor air. The concentrations, however, are well below the legal limits for occupational exposure.
2.0 OBJECTIVE
The purpose of the indoor air surveys and sampling events will be to determine whether concentrations of volatile organic compounds (VOCs) in indoor air within the O'Gara training facility exceed the legal limits for occupational exposure.
3.0 METHODS
Site Evaluation
On behalf of O'Gara, ECS conducted a site evaluation on June 15, 2012 to determine if indoor air concentrations of V O C s pose an unacceptable risk to site workers and if increased building ventilation would be sufficient to reduce indoor air VOC concentrations.
AR100051
ECS Project No. 19321 August 31, 2012
- 2 -
The site evaluation was conducted using a ppb-RAE 3000, a photoionization detector (PID) with an extended range of 1 part per billion (ppb) to10,000 ppm. In addition to ambient air readings,, the PID was used to determine the concentration of VOCs in air at locations where vapor intrusion of VOCs was most likely to occur, including joints in the concrete slab, floor drains and at gaps or cracks in walls.
Similar to previous sampling results, the PID indicated that low levels of VOCs were present in indoor air at the former manufacturing facility. Field screening results are summarized in Table 1. The highest concentrations of VOCs were observed in the in the northwest corner of the building, where a soil vapor extraction (SVE) system formerly treated VOCs in soil (Operable Unit 1). This area of the building is locked, and not generally accessed as part of O'Gara's operations. Concentrations observed elsewhere in the building were less than 1 ppm, indicating that the concentrations within the facility were below occupational standards.
During the site visit ECS observed the ventilation systems serving the building. In general, the only conditioned spaces observed were the main front offices and one storage area, which is also located in the front section of the building. ECS observed two separate air handling units serving the front office areas, with one air handler located near the break/training room, and the other located near the NE section of the building near the restrooms. A separate HVAC unit was also observed servicing a section of the front of the building currently being used for storage (this area was formally part of the factory floor space). With respect to the remainder of the building, in general it appears natural draft ventilation is used for ventilation. This basically includes roof top dormer vents and wind driven "turbo" or natural forced air roof vents, and cracks and leaks around doors and windows also providing some air into the building. During our site evaluation, ECS also observed that some areas of the main factory floors have been converted to smaller offices with local air conditioning units serving these office areas.
At this time ECS recommends that O'Gara consult with a qualified mechanical contractor to evaluate the present ventilation system(s) serving the building. With respect to the two systems serving the front offices, ECS did not observe outside make-up air for the units. Under ASHRAE 62 2004, recommended minimum ventilation rate is 5 cubic feet per minute per occupant of outside air plus an additional 0;06 CFM per square foot of space (reference ASHRAE 62.1:2004 - for typical office use). With regards to the remainder of the building space, since it is a mixture of storage, shops, training areas etc, although not required, the facility may again want to consult with a qualified mechanical contractor for an assessment of proper ventilation needs for the different spaces and the intended use for each space. With regards to the sites former legacy usage and the concern that hazardous pollutants located under the floor slab may accumulate within the building, adequate fresh outside air ventilation (both of movement of fresh outside air into the building along with good air movement to circulate and exhaust building air to the outside) would help in reducing concentrations of airborne pollutants in the building.
AR100052
ECS Project No. 19321 August 31, 2012
- 3 ...
Indoor Air Sampling
To monitor the concentrations of VOCs within the facility, ECS proposes collecting five indoor air samples on a quarterly for one year basis. The quarterly results will be used to determine seasonal variations in the concentrations of VOCs within the building and to verify that the concentrations remain below the OSHA limits for occupational exposure.
Evacuated Summa canisters will be placed within the former manufacturing facility and in the office, at locations shown on Figure 1. At the time of the sample collection, ECS will also perform a survey of the building using a ppb-RAE PID. The PID will be equipped with a 10.6 electron-volt lamp in order to detect VOCs at the parts per billion (ppb) levels. The PID will provide real time data and identify areas of potential sources of sample interference. All canisters will be placed in the breathing zone of the onsite site workers, approximately three to four feet above the ground. Prior to the sampling event, on-site workers will be notified of the purpose of the sample collection and will be instructed not to tamper with the sampling devices or perform activities within the sample areas which may interfere with sample results. The 1-liter canisters will have a vacuum of 30 inches of mercury. The sample period will last for 24-hours, allowing for approximately 5 inches of mercury to remain in the canister at the end of the sampling period, at-which time the flow into the canisters will be stopped. The canisters will be submitted to Centek Laboratories in Syracuse, New York, for analysis of VOCs by EPA method TO-15. The method detection reporting limits are included in Appendix I and the laboratory's accreditation certificate is included in Appendix II. .
4.0 REPORTING
ECS will prepare quarterly reports summarizing the indoor air sampling results. As discussed previously, the EPA's indoor air sampling results demonstrate that concentrations of VOCs within the facility are well below the legal limits for occupational exposure. The quarterly report will continue to provide a comparison to applicable OSHA PELs to verify that concentrations of compounds within the O'Gara facility do not exceed these legal limits for occupational exposure.
5.0 SIX MONTH PROJECT TIMELINE
August 2012
• Present the Work Plan for Indoor Air Sampling to the EPA for review.
September 2012
• Qualified mechanical contractor performs evaluation of ventilation capabilities of the building and, if possible, increase ventilation.
AR100053
ECS Project No. 19321 August 31, 2012
- 4 -
• Complete a site survey with a PID and collect indoor air samples in five locations within the building.
October 2012
• Summary report of indoor air sampling results prepared
November 2012
• No activity.
December 2012
• Monitor indoor air with a PID and collect indoor air samples at the same five locations that were sampled during September 2012
January 2013
• Summary report of indoor air sampling results prepared
AR100054
Table 1 Site Survey PID Recordings
Location PID (ppb) Notes
Steel pipe In floor NW corner ambient
NWwall joint (1) NW wall joint (2)
387,000 62 345 60
NW corner of building NW corner of building NW corner of building NW corner of building
NW floor drain 600 NW corner of building
NW ambient 70 NW corner of building
NW floor joint 300 NW corner of building
Front office wall joint (1) 60 Front office
Floor drain 260 South of front office
Front office wall joint (2) 387 Front office
Front office ambient Front office wall joint (3)
82 75
Front office Front office
Front office slab crack 300 Front office
Western wall, ambient (1) 15 Near door exterior door
Western wall, ambient (2) Floor drain
24 24
Near door exterior door near western wall
Floor drain 17 near western building wall
Slab crack near western building wall
Large open space ambient (1) Large open space ambient (2)
114 90
ambient ambient
Doorway to warehouse Former Caustic room
207 18
near front office caustic room
Next to former caustic room Interstitial between walls
20 44
caustic room near front office
AR100055
AR100056
APPENDIX I
TO-15 LABORATORY DETECTION LIMITS
t
AR100057
Centek Laboratories, LLC Date: 2012
Test Code: lugM3_T015w/Naph M E T H O D D E T E C T I O N /
Test Number: TO-15 R E P O R T I N G L I M I T S
Test Name: lug/M3w/ Naphthalene by Method TO 15
Matrix: Air Units: ppbV
Type Analyte MDL PQL
A 1,1,1-Trichloroethane 0.057 0.15 A 1,1,2,2-Tetrachloroethane 0.084 0.15 A 1,1,2-Trichloroethane 0.088 0.15 A 1,1-Dichloroethane 0.043 0.15 A 1,1-Dichloroethene 0.034 0.15 A 1,2,4-Trichlorobenzene 0.145 0.15 A 1,2,4-Trimethylbenzene 0.092 0.15 A 1,2-Dibromoethane 0.068 0.15 A 1,2-Dichlorobenzene 0.094 0.15 A 1,2-Dichloroethane 0.066 0.15 A 1,2-Dichloropropane 0.094 0.15 A 1,3,5-Trimethylbenzene 0.087 0.15 A 1,3-butadiene 0.077 0.15 A 1,3-Dichlorobenzene 0.103 0.15 A 1,4-Dichlorobenzene 0.098 0.15 A 1,4-Dioxane 0.097 0.3 A 2,2,4-trimethylpentane 0.043 0.15 A 4-ethyltoluene 0.098 0.15 A Acetone 0.09 0.3 A AUyl chloride 0.092 0.15 A Benzene 0.059 0.15 A Benzyl chloride 0.075 0.15 A Bromodichloromethane 0.062 0.15 A Bromoform 0.075 0.15 A Bromomethane 0.051 0.15 A Carbon disulfide 0.098 0.15 A Carbon tetrachloride 0.048 0.04 A Chlorobenzene 0.086 0.15 A Chloroethane 0.077 0.15 A Chloroform 0.054 0.15 A Chloromethane 0.066 0.15 A cis-l,2-Dichloroethene 0.047 0.15 A cis-l,3-Dichloropropene 0.096 0.15 A Cyclohexane 0.048 0.15 A Dibromochloromethane 0.062 0.15 A Ethyl acetate 0.092 0.25 A Ethylbenzene 0.072 0.15 A Freonll 0.028 0.15 A Freonll3 0.101 0.15 A Freonll4 0.044 0.15 A Freonl2 0.043 0.15 A Heptane 0.092 0.15
I of 2
AR100058
Centek Laboratories, LLC Date: 2012
Test Code: lugM3_T015w/Naph
Test Number: TO-15
Test Name: 1 ug/M3 w/ Naphthalene by Method TO 15
Matrix: Air Units: ppbV
Type Analyte
METHOD DETECTION / REPORTING LIMITS
MDL PQL
A Hexachloro-l,3-butadiene A Hexane A Isopropyl alcohol A m&p-Xylene A Methyl Butyl Ketone A Methyl Ethyl Ketone A Methyl Isobutyl Ketone A Methyl tert-butyl ether A Methylene chloride A Naphthalene A o-Xylene A Propylene A Styrene A Tetrachloroethylene A Tetrahydrofuran A Toluene A trans-l,2-Dichloroethene A trans-l,3-Dichloropropene A Trichloroethene A Vinyl acetate A Vinyl Bromide A Vinyl chloride I 1,4-Difluorobenzene I Bromochloromethane I Chlorobenzene-d5 S Bromofluorobenzene
DEPARTMENT OF GENERAL SERVICES DIVISION OF CONSOLIDATED LABORATORY SERVICES
Certifies that
VA Laboratory ID#: 460228 CENTEK LABORATORIES, LLC
143 MIDLER PARK DRIVE SYRACUSE, NY 13206
Owner: JAN SCALA Operator: RUSS PELLEGRINO Responsible Official: RUSS PELLEGRINO
Having met the requirements of 1 VAC 30-46 and the National Environmental Laboratory Accreditation Conference 2003 Standard
is hereby approved as an
Accredited Laboratory
As more fully described in the attached Scope of Accreditation
Effective Date: May 14, 2012
Expiration Date: March 14, 2013
Certificate # 1536
Continued accreditation status depends on successful ongoing participation in the program. Certificate to be conspicuously displayed at the laboratory. Not valid unless accompanied by a valid Virginia Environmental Laboratory Accreditation Program (VELAP)
Scope of Accreditation. Customers are urged to verify the laboratory's current accreditation status.
,,/brk, Ph.D., HCLD DGS Deputy Director for Laboratories
Certificate Not Transferable Surrender Upon Revocation AR100061
CENTEK LABORATORIES, LLC 143 MIDLER PARK DRIVE SYRACUSE, NY 13206
Commonwealth of Virginia ' ^^£%jp>\f Department of General Services
Division of Consolidated Laboratory Services
Scope of Accreditation
VELAP Certificate No.: 1536 I
Virginia Laboratory ID: 460228 Effective Date: May 14, 2012
' Expiration Date: March 14, 2013
TlJmasL^^^D., HCLD DGS Deputy Director for Laboratories
AIR METHOD
EPA TO-15 1999
EPA TO-15 1999
EPA TO-15 1999
EPA TO-15 ?999*
ANALYTE 1.1,1 -TRICHLOROETHANE
" T ^ T R I C ^ ^ O E T H A N E ( F R E O N 113)
PRIMARY, NY
1,1-OICHLOROETHANE
EPA TO-15 1999 1,2-OIBROMO-S-CHLOROPROPAN
EPA TO-15 1999 1,2-DICHLOROBENZENE
NY NY"
W
"W
EPA TO-15 1999 1,2-OICHLOROPROPANE
EPA TO-15 1999 1,3-BUTAOIENE
EPA TO-15 1999 1,4-DICHLOROBENZENE
EPA TO-15 1999 2,2,4-TRIMETHYLPENTANE
EPA TO-15 1999
EPATO-15 1999
4-METHYL-2-PENTANONE (MIBK)
"ACETOPHETioNE" " ""~
EPATO-15 1999 BENZENE
EPATO-15 1999
EPAT^~TT7999"
E?AT^75^999~
BROMODICHLOROMETHANE
"CARBON DISUUFTDE" CHLOROACETIC ACID
EPATO-15 1999
EPATO-15 1999
EPA TO-15 1999~
EPA TO-15-"l999"
EPATO-15~1999
EPA TO-'iTTgsST EPATO-15 1999*
EPATO-15 1999"
EPATO-15 1999
EPATO-15"l999~
CHLOROETHANE(ETHYL CHLORIDE) _ _____ c is - i . 2 - D I C H L O R 6 E T H Y L E N E " "*
