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Unfolding Disaster:
A Study of Chemplast Sanmar’s Toxic Contamination in Mettur
Community Environmental Monitoring & Corporate Accountability Desk
Programs of the Other Media
November 2007
Acknowledgements:
West Gonur Farmers’ Welfare Association
Piyush Sethia, SpeakOut Salem!
Dr. Mark Chemaik, Staff Scientist, ELAW-US
Environmental Law Alliance-US
Ruth Stringer, Independent Scientist
Dr. Rakhal Gaitonde, Community Elealth Cell, Chennai
V. Mayilsami, Chairman, P.N Patti, PMK
A. Marimuthu, Ward Councillor, P.N. Patti
P.N. Patti Panchayat
T.S.Mani, Periyar Dravida Kazhagam
Association for India’s Development, Austin, Texas
Global Greengrants Fund
Marisla Foundation
Written by: Lakshmi Premkumar
Edited by: Nityanand Jayaraman
Sampling Team:
Dharmesh Shah
Shweta Narayan
Lakshmi Premkumar
Jeny Dolly Anthony
Nityanand Jayaraman
Piyush Sethia
Ruth Stringer
Special thanks to Ruth Stringer and Mark Chemaikfor their scientific inputs and oversight, and to ELAWUSfor their techno-legal advice and assistance with funding.
Photo: Nityanand Jayaraman, Shweta Narayan, Dharmesh Shah
Design & Layout: Think Communication
Cover: Art by Blodsow
Cover Design: Sibi Arasu
1
Addendum (12 November, 2007)
Fresh results received on 8 November, 2007, confirm
the presence of high levels of dioxins and furans in
Mcttur’s environment. A composite sample of soil
and sediment taken from two rainwater drains emp
tying. into a stream that ends up in the River Kaveri
was found to contain 6.7 nanogram/kg of total dioxins
and furans. [See Annexure 5] This is at least 8 times
higher than Canadian interim sediment quality stan
dards of 0.85 ng/kg. Dioxins and furans belong to a
category of chemicals known to contain some of the
most toxic chemicals known to science.
The very presence of dioxins and furans is cause for
concern. The fact that these chemicals were found in
water courses that empty into the River Kaveri has se
rious implications for agriculture, dairy industry and
fisheries. Dioxins and furans are persistent in the en
vironment. They accumulate in the fatty tissue of liv
ing organisms growing in quantity within the fat over
the lifetime of the organism. Levels of these chemi
cals also increase as one goes up the food chain as
predators higher up in the food chain feed on several
smaller organisms thereby absorbing their combined
body burden of dioxins and furans. Levels in preda
tory fish and in the milk and meat of goats and cows
feeding of contaminated areas can be passed on to hu
mans through the food chain.
On October 16, 2007, Specialty Analytical - the Or
egon, US-based laboratory that performed the analy
ses of samples taken from Mettur — sent a composite
sample of sediment/soil taken from two locations,
namely Sample CP07004 and CP07006, to Pace Ana
lytical Services, Minneapolis, for dioxin/furan analy
sis. The above two samples were stored by Specialty
as per their routine protocol to allow their clients to
opt for additional testing. The composite sample was
analyzed for the presence or absence of polychlorodibenzo-p-dioxins (PCDDs) and polychlorodibenzofurans (PCDFs) using a modified version of USEPA
Method 8290.
These two samples were considered to be good can
didates for dioxin analysis because CP07004 has
moderate levels of hexachlorobenzene (HCB) and
hexachlorobutadiene (HCBD) — at 819 and 164 ppb
respectively — and Sample CP07006 has relatively
high levels of di-and tri-chlorobenzenes (>5 ppm cu
mulatively). The presence of higher chlorinated aro
matics such as HCB and HCBD, and chlorobenzenes
in substantial quantities is an indicator of the likely
2
presence of dioxins. Also, PVC factories are known
sources of dioxins.
A detailed study focusing on dioxin contamination
in and around Chemplast’s PVC factory, and particu
larly on the river downstream of the factory’s effluent
outfall in Kaveri is an urgent need.
The original lab report in its entirety can be down
loaded from the Reports section of www.sipcotcuddalore.com.
Executive Summary:
In 2007, Mettur-based West Gonur Farmers Welfare
Association contacted Chennai-based Community
Environmental Monitoring to verify:
1. whether the “treated” waste water discharged
legally to the River Kaveri by Chemplast
Sanmar Ltd’s PVC factory was safe,
2. whether any other illegal channel existed
through which toxic effluents were being
released into the environment, and
3. whether reports of toxic contamination of well
water were true.
The District Administration and the Tamilnadu
Pollution Control Board (TNPCB) have routinely
responded to people’s complaints about pollution by
stating that the only discharge of effluents is through
the legally approved pipeline, and that this discharge
is within safe limits. Tests conducted by the TNPCB
and other agencies on well water have only analysed
for simple parameters such as dissolved salts and
electrical conductivity. Reports of contamination of
groundwater by organic chemicals have not been
looked into to this date.
In Mettur, Chemplast produces chemicals such as
chlorine, caustic soda (through the mercury route),
chloromethanes, ethylene dichloride (EDC), vinyl
chloride monomer (VCM), Poly Vinyl Chloride
(PVC), and chloro fluoro carbons.
In July 2007, Community Environmental Monitoring
sent samples of effluents, well water, sediment and
soil from in and around Chemplast’s chemicals
manufacturing complex for scientific analyses at
a United States Environmental Protection Agency
(USEPA)-approved laboratory in Oregon, U.S.A.
The results revealed that Chemplast’s operations have
and are contributing to the widespread contamination
of Mettur’s environment with mercury and a host of
toxic chlorinated chemicals, including potentially
dioxins. Also, the results of analyses are conclusive
that Chemplast’s treated wastewater contains unsafe
levels of toxic chemicals, and that well and borewell
water were indeed contaminated by a host of synthetic
poisons. While evidence is conclusive that channels
other than the legally approved pipeline have been
used to discharge toxic effluents, it is unclear whether
the contamination found in these channels and
natural drainages was a result of historical or ongoing
discharges of effluents.
Undertaken at the request of the West Gonur Farmers
Association, the exercise detected 52 chemicals in the
nine samples taken in Mettur. Of these, 17 chemicals
were found to be above one or more of four safety
levels prescribed by various international regulatory
agencies.
These chemicals are:
• Mercury
• 1,2,4-trichlorobenzene
• 1,2-Dichlorobenzene
• 1,4-Dichlorobenzene
• Bis(2-Ethylhcxyl)Phthalate
• Hexachlorobenzene
• Hexachlorobutadiene
• Bis(2-chloroethyl)cther
• Chlorobenzene
• 1,1,2-Trichlorocthane
• Ethylene Dichloride
• Benzene
• Vinyl Chloride
• Chloroform
• Methylene Chloride
• Tetrachloroethane
• Trichloroethane
Twelve of the 17 chemicals are known to cause cancer
in humans and/or animals.
The presence of hexachlorobutadiene (HCBD) and
hcxachlorobenzene (HCB) in the sediment taken from
an open stormwater course between Chemplast’s Plant
11 and Plant III, and the high levels of dichlorobenzenes
found in the stormwater drain leaving Plant II is cause
for serious concern. These indicate a high likelihood
of the presence of dioxins and furans, some of the
most toxic chemicals known to science. Also, HCB
is a Persistent Organic Pollutant (POP) — a category
of chemicals identified for global phase out under the
Stockholm Convention owing to their persistent and
highly toxic nature. POP chemicals include some of the
most poisonous and unmanageable chemicals - such
as HCB, dioxins and furans — known to science.
Even more alarming is the fact that very high levels of
poisons, such as chloroform and methylene chloride,
tetrachloroethane and vinyl chloride were found in
the water from a 500 foot borewell. This confirms the
fact that groundwater contamination has seeped to
very great depths.
3
- .~e narcre an; extent of contamination, :«•<•» in lip,hl
cl '_"e other evcetice of pollution in Mellin piovidv
*
.
*
su~cieu
ca_se to nominate Mettur us n globul
Toxic Hxspoi thai caalines for inclusion in the lisl
c* “critically pcTuied areas” of the Central Pollution
Control Board.
•ilml\ i<■ |»<<i(«■<I 11>• |!ii jii'< '/I hczachlorobutadiene,
iiinonp. i>ih< i i In mu als, in ih1 effluent's and sediment
limn tin |’V( pl.mi .ii ilic point of discharge into
Unit Kiivrii III HI) is a knov/n animal carcinogen
mill iii<Ih ales lli<- pir'.cncc <>l dioxins.
On Apnl 5, 2005, Chennai based Community
AT samples were taken on 24 July, 2007 in the presence liiviionmcnlal Monitoring look an air sample from
of an elected iocal Government official, members of lhe vicinity of (hemplast Sanmar’s PVC effluent
the farmers' association, and a trained scientist with discharge point in the River Kaveri. Four of the
specialisation in chlorine chemistry. The findings arc compounds found in the sample are manufactured in
in Ice with earlier studies conducted on Mcttur’s one or other Chcmplast units. These include: vinyl
emriromneti. and with what can be expected to be chloride, ethylene dichloride (EDC), methylene
found its rt environment around plants manufacturing chloride and chloroform. All four are animal and/
chlorinated organic chemicals, including PVC. The or human carcinogens. EDC was more than 32,000
chemicals found are those used in the manufacturing times above a US Environmental Protection Agency
process or those that are released as by-products or (USEPA) safety level. Vinyl chloride was 2100 times
end-products during the manufacturing process. above safety level, and hydrogen sulphide was 400
However, their presence at such high levels in the times more than levels above which health effects
environment around the industry and surrounding occur.2 Benzene, chloroform and methylene chloride
areas show that precautionary measures in handling were also found above regulatory levels set by the
and disposing the toxic chemicals are not followed.
USEPA. India has no prescribed standards for most of
these pollutants in ambient air.
Most chlorinated organic compounds are toxic
pollutants. Many of them are persistent, do not break In 2005, the Indian Peoples Tribunal (IPT)3 described
down easily, and have a tendency to accumulate in “the appalling scenario prevalent in Mettur of
animal tissue. The concentrations of the chemicals get indiscriminate disposal and mismanagement of
higher as they move up the food chain. The presence hazardous wastes and the resultant devastation of
of such chemicals in the environment is of particular environment and public health at Mettur.” The report
concern to the economy of Mettur, in which agriculture also brought to light the apathy and callousness
and fishing continue to play an important role.
with which the concerned authorities, government
and industry officials dealt with pollution related
Official reports, including those from the Tamilnadu complaints and issues.
Pollution Control Board, in the possession of the
West Gonur Farmers Association confirm widespread Given that the first evidence of the discharge of
contamination of wells in Gonur, Veerakalpudur and highly toxic effluents by Chcmplast into the River
P.N. Patti panchayats.. However, none of these reports Kaveri emerged in 1997, more titan a decade ago, it
tested for. my of fre chlorinated organic chemicals is unfortunate that the plant continues its discharge
that can he expected from facilities such as those run unchecked. The widespread presence of mercury in
by Cbezoplast in .Mettur.
the vicinity of the Stanley Reservoir, a waterbody
of critical importance, the continued discharge of
In 1996. a Greenpeace study' reported the presence persistent organic pollutants into the River Kaveri and
of chemicals such as mercury in sediments below the high levels of toxic chemicals such as chloroform
the chloralkali plant effluent discharge point into the and benzene found in groundwater points to potentially
Kaveri at more than 500 times than what is expected irreversible damage to the local environment and
community health. This damage may extend beyond
in uncontaminated river sediments.
Mettur to those relying on Kaveri water for drinking
PVC factories are a well-known source of hazardous and agriculture, and those consuming agricultural
organochlorines, including dioxins. The Greenpeace produce and fish from these areas.
2
4
'"The Stranger-The Chlorine Industry In India", Greenpeace International, 1996. Page 21 <£ 66
- "The Indian People s Tribunal report- on Environmental and Human Rights Violations by Chcmplast Sanmar and MALCO industries at Mettur,
Tamil Nadu ", Indian People s Tribunal on Environmental and Human Rights, 2005. Page 16
' Indian People s Tribunal Report, 2005. Page 1
Most research has been done on the effects of
individual chemicals on the human body. However,
in real life, humans are usually exposed to cocktails
of chemicals. While the focus of the discussions in
this study has been on the chemicals found above
standards, the mere presence of highly toxic and
persistent chemicals like pentachlorophenol and
hexachloroethane is cause for concern.
“The widespread presence of excessive levels of at
least 17 chemicals with known harmful effects, and
the possible combined effect of long-term exposure to
a cocktail of 52 chemicals albeit at low concentrations
points to nothing less than a potential public health
disaster,” according to Dr. Rakhal Gaitonde, a public
health expert who reviewed the report. “Unless this
dangerous situation is addressed urgently, there is
potential for serious, unpredictable and potentially
irreversible consequences, as well as long term
damage to the environment, livelihoods, food and
water security,” he concludes.
Based on the evidence generated by the current study,
and other studies to this date, it would be prudent to
apply the precautionary principle by taking immediate
steps to do the following:
1. End discharge of effluents into the River Kaveri
2. Conduct a comprehensive and independent
assessment of the spread and depth of contamination,
including of groundwater, water courses leading from
the factory to the River Kaveri, of environment and
fish downstream of Chemplast’s effluent discharge
point, and of reservoir and reservoir fisheries. The
assessments should be conducted with a particular
focus on persistent, bioaccumultative poisons such as
dioxins and furans, and mercury.
3. Initiate a comprehensive clean-up involving local
communities.
4. Assess impact of pollution on the health of people
in Mettur. Set up a long-term health monitoring
and remediation infrastructure to identify and assist
affected persons at the cost of the polluter.
5. Arrange for immediate delivery of clean water
for domestic purposes to affected communities and
recover costs from the polluter.
6. Initiate legal action and criminal prosecution of
the polluter for negligent handling of chemicals and
violation of environmental regulations.
7. Set up and enforce standards for organohalogens in
various relevant media, including, soil, air, sediment,
effluents and water.
8. The Central Pollution Control Board should declare
Mettur a “Critically Polluted Area.”
9. The Kaveri Government Order prohibiting the
expansion or setting up of new polluting industries
should be implemented earnestly.
10. Strengthen public health systems to undertake
research and treatment of these pollution related
problems.
Introduction
notified rivers, including the Kaveri and its tributaries,
in Tamil Nadu. This order has had no effect in curtailing
expansion of polluting industries or the setting up of
new ones near Kaveri. The three largest companies
in Mettur, namely Chemplast, Madras Aluminum
Company and the Mettur Thermal Power Plant, have
According to the 2001 Census of India, Mettur had a all expanded their projects in recent years in violation
population of 3,78,337 with an average literacy rate of of the Government Order.
56 percent. Agriculture, fishing and industries are the
main contributors to the economy. The 2001 Census Industries in Mettur
registers that half the population i.e., 49 percent,
Among the first things that greet the Kaveri as she
directly depends on agriculture for their income.
enters Tamilnadu at Mettur is the toxic effluents from
The Mettur Dam which forms the Stanley Reservoir more than half a dozen major industrial operations
was built in 1934, across a gorge where the River including five units owned by Chemplast Sanmar, one
Kaveri enters the plains. It is a major source of owned by MALCO, and two thermal power plants
drinking water. According to Professor Janakarajan, owned by MALCO and Tamilnadu Electricity Board.
Madras Institute of Development Studies, the Kaveri
irrigates 24 lakh acres of land across central and Industrialisation in Mettur began as early as 1936,
when Mettur Chemicals and Industries Corporation
eastern Tamilnadu.
(MCIC), now Chemplast Sanmar, set up India’s first
Bloody riots over the sharing of Kaveri’s waters caustic chlorine factory. Over the years, Chemplast
between the riparian states of Tamil Nadu and Sanmar added a range of facilities including a
Karnataka are an annual feature. However, this is chloromethanes plant, and a PVC plant including
not the only source of conflict concerning Kaveri’s units to produce ethylene dichloride (EDC) and
waters. Throughout Kaveri’s course in Tamilnadu, vinyl chloride monomer (VCM). Madras Aluminum
farmers are up in arms against polluting industries Company (MALCO) set up a refinery-cum-smelter
near the reservoir in 1965. A number of chemical
that use this river as a dump for effluents.
industries were set up on the banks of the River Kaveri
Stretches of the Kaveri are deemed to be among the in Mettur as part of Small Industries Development
“most polluted zones of the state,” according to a Corporation (SIDCO) industrial estate.
State of Environment of Tamilnadu report released in
2005.4 At least 1100 industries operate in the Kaveri Most of the industries are clustered around three
basin, according to a Tamilnadu Pollution Control Panchayats (units of local self-government) - P.N.
Board (TNPCB) survey mentioned in the State of Patti, Veerakalpudur and Gonur. The combined
Environment report. The estimated waste water population of these Panchayats is 55,855.
Mettur literally means ‘town on the hills.’ Once an
agricultural area, Mettur now hosts a number of
chemical industries and a dam. The River Kaveri, the
life line of north and central Tamilnadu, enters the
south Indian state through Mettur.
discharge is 16.2 crore litres per day (Ipd). Of that,
870 lakh Ipd is discharged directly into the Kaveri.
Salem district, with 640 lakh Ipd, followed by Trichy
(57,64,000 Ipd) are the largest contributors of effluent
to the Kaveri, according to the report.
A Government order5 dated 8.5.98 stipulates that
no permission should be granted to establish water
polluting or “Red” category factories within 5 km of
Chemplast’s Plant 2 and Plant 3 are the key units
dealing with chlorine and chlorinated organic
chemicals. Plant 2 manufactures ethylene di chloride,
vinyl chloride monomer and poly vinyl chloride.
Plant 3 manufactures chlorinated solvents such as
carbon tetrachloride, methylene chloride, chloroform
and chlorine and caustic soda through the mercury
cell route.
‘ "State ofEnvironment of Tamil Nadu", Dr. S. Balaji, IFS, Department ofEnvironment, Government of Tamil Nadu. Undated. Release date:
2005. http://www.environment.tn.nic.in/soe/soe_report.htm. Downloaded3 October, 2007.
’ G.O. Ms. No. 127, Department ofEnvironment and Forest, Government of Tamil Nadu, 08.05.1998
2 6
Chemplast Sanmar & its units in Mettur
Diagram no. 1
Production Capacity at Chemplast Sanmar Ltd.
Table no.1
PVC
Caustic Soda
Capacity T/A
78160
68640
66000
43680
Chlorine
30% HCL
Methyl Chloride
Methylene Chloride
Chloroform
Carbon Tetrachloride
Silicon Tetrachloride
Trichloroethylene
Perchloroethylene
Dichloroethylene
Tetrachloroethane
38700
50880
1200
9408
7056
7728
1008
4950
77.52
48
6326.76
Plant Product
2
EDC
VCM
3
Source: Tamilnadu Pollution Control Board
taken from two effluent streams discharging to an open
channel ultimately leading to the Kaveri contained 1.09
milligram/litre and 149 micrograms/litre of mercury
respectively. "The higher value is more than 20 times
greater than the [European Community] permitted
maximum” and grossly violates Central Pollution
Control Board norms, Greenpeace concludes.
PVC factories are a well-known source of hazardous
organochlorines, including dioxins. The Greenpeace
study reported the presence of hexachlorobutadiene
(HCBD), among other chemicals, in the effluents
from the PVC plant at the point of discharge in River
Kaveri. HCBD is a known animal carcinogen and
indicates the presence of dioxins.
In April 2005,
Chennai-based
Community
Environmental Monitoring took an air sample from
the vicinity of Chemplast Sanmar’s effluent discharge
point in the river Kaveri. The sample was analysed
by the Columbia Analytical Services Laboratory in
California. The analysis identified 17 chemicals. At
least four of the compounds found are manufactured
in one of the Chemplast units. These include: vinyl
chloride, ethylene dichloride (EDC), methylene
Samivelu was exposed during a chlorine gas leak in 2004 from
Chemplast Plant 3 when he was 22 days old; his physical
development is retarded and he continues to consume large
quantities of medicines to date.
Studies conducted in Mettur
Since the early 1960s, local communities have reported
incidents of pollution and pollution induced damage
to agriculture and the health of livestock as well
as humans. In a few instances, they have also been
awarded compensation for affected land and wells.6
Over the last five decades, numerous complaints have
been filed. Several agencies have analysed well water
and soil quality. A 1995 sampling exercise by the Soil
Testing Laboratory, Salem, confirmed the degradation
of all 51 irrigation wells sampled in the vicinity of
Chemplast.7
A 1996 Greenpeace study8 reported the presence
of chemicals such as mercury in sediments below
the chloralkali plant effluent discharge point, at
more than 500 times the levels that are expected in
uncontaminated river sediments. Two other samples
PVC Effluent outlet into River Kaveri
* Revenue Divisional Officer, Mettur. Order No. ROC 9468/66 (P3). 10.9.66.
’Report of Analyses via Letter dt/24.7.95 from Assistant Soil Chemist, Soil Testing Laboratory, Salem, to Village Residents, Thippampatti
Kattuva/avu, Gonur.
‘ The Stranger-The Chlorine Industry In India ", Greenpeace International, 1996. Page 21 & 66.
i 8
Table 2: Chemicals Detected in Air Sample near Chemplast Sanmar’s
PVC Effluent Outfall, April 2005
Number of times
above screening
levels
Hydrogen Sulphide
Carbon di sulphide
296
19.5
Vinyl Chloride
*
Ethanol
Acetone
Isopropyl Alcohol
Methylene
*
Chloride
1-1, Dichloroethane
n-Hexane
*
Chloroform
1,2*
Dichloroethane
*
Benzene
1,1,2*
Trichloroethane
Toluene
Chlorobenzene
o-Xylene
1,2,4Trimethylbenzene
470
180
36
6.8
6.7
USEPA Region 6
Screening Levels
(microgram/cubic
meter) unless specified
otherwise
1.00
3 (Texas Long-term
screening levels)
0.220
—
370
—
4.09
26
6.8
32
2400
520
210
0.0840
0.0740
—
—
381
32,432
6.4
8.7
0.250
0.120
25.6
72.5
27
6.1
16
5.5
400
63
730
6.2
—
—
—
--
Levels Detected
Chemicals
Detected
296
6.5
2136
—
—
1.64
* Animal and/or human carcinogen
chloride and chloroform. All four are animal and/or
human carcinogens. EDC was found at levels 32,000
times above the USEPA’s Region 6 Screening levels.
Vinyl Chloride was more than 2100 times above the
same levels. Hydrogen sulphide, a toxic gas capable
of damaging the brain, was 296 times higher than
screening level.9 Screening levels are those levels
above which health effects may occur. (Refer Table
No.2)
In July 2005, at the request of a Mettur-based
community group and other voluntary groups from
Tamilnadu, the Indian People’s Tribunal on
Environment and Human rights (IPT) headed by Justice
(Retd) Akbar Basha Kadri visited Mettur to assess
alleged human rights and environmental violations
by Chemplast and Malco. Describing the “appalling
scenario prevalent in Mettur of indiscriminate disposal
of hazardous wastes and the resultant devastation of
environment and public health at Mettur,” the report
highlighted “the apathy and callousness with which
the concerned authorities, government and industry
officials dealt with the pollution related complaints
and issues.”10
’ Reported in "Smokescreen: Ambient Air Quality in India. " March 2007. Page 15-16.
9
The panel concluded that the Chemplast’s discharges
have seriously impacted the ecology, human and
animal health, agriculture, livelihoods and socio
economic status ofMettur. Justice Kadri recommended
the provision of clean water for the communities,
the initiation of long-term health monitoring and
rehabilitation; clean up of contaminated sites and
groundwater and compensation to affected parties.
However, none of these reports have had any effect
on regulator}' agencies and the district administration.
Rather than curb pollution, the company is being
allowed to expand. Even in the face of repeated
complaints from residents that Chemplast is
discharging effluents illegally through streams and
canals, the Tamilnadu Pollution Control Board
continues to assert, without investigation, that all
Effects of Pollution
Decline in fishing
• A fish diversity study10
11, confirms that though the fish diversity in the reservoir is healthy, the
down stream of Kaveri, beneath Chemplast’s effluent discharge points is characterised by low or
no fish population.
• On 24 November, 2004, and 14 July, 2006, massive fish deaths occurred downstream of
Chemplast’s effluent discharge point. No punitive action was taken against the company.
Impacts on Agricultural Economy
• Farmers report that contamination of groundwater and soil has led to large-scale decline in agri
cultural productivity
• The cattle economy has also been devastated. Occurrence of calf-mortality is high while milk
yield is low.
Health
• Skin ailments, bloated stomachs, respiratory disorders, cancers, tumours, and dental problems
are the most common symptoms that people from the community experience. Irregular menstrual
cycles with 10 to 15 days of bleeding, two periods a month and frequent occurrences of miscar
riages are reportedly high among women.
• IPT reports that, on average, families spend Rs.900 per month on groceries and Rs. 1200 per
month on medical treatment.
Gas Leaks
Incidents of gas leaks from the company are said to be frequent consequences of production be
yond rated capacity, poor maintenance of equipment, inexperienced workers, low manpower, and
negligent and carel ess haaidling of chemicals within the factory.
• On 18 July, 2004, following a chlorine gas leak from the company, at least 100 people were
exposed to the gas and more than 20 were hospitalized, including a 22 day old child.
• On 27 September, 2007, a similar incident involving a Chlorine gas leak from the company oc
curred.
• On 02 January, 2007, large quantities of flyash released from Chemplast cost health problems in
Gonur, Veerakal Pudur and P N Patti Panchayats.
Source: IPT and local reports___________________________________________________________
10 Indian People s Tribunal Report, 2005. Page 1
“ M. Arunachalam and M. Muralidharan. "Histological study on kidney, gill and intestine of two species offish collectedfrom the confluence of
effluent discharge from Chemplast Sanmar group of Companies into the Kaveri River ", Sr Paramkalyani Centre for Environmental studies, July
10
trade effluents are discharged through a legallysanctioned pipeline into the surplus course of the
Kaveri.12
Introduction to the Study
In early 2007, West Gonur Farmers Welfare
Association, an organisation in Mettur, contacted
Community Environmental Monitoring(CEM) to
verify:
whether the treated waste water discharged legally
to the Kaveri by Chemplast was safe,
• whether any other illegal channel existed through
which toxic effluents were being released into the
environment and
• whether reports of toxic contamination of wells
were true.
•
In June 2007, CEM worked with two experienced
scientists — Ruth Stringer and Mark Chemaik - to
develop a protocol for sampling. The former has more
than a decade’s experience sampling and analysing
industries manufacturing chlorinated chemicals,
including PVC, and is co-author of an authoritative
overview of the chlorine industry called “Chlorine and
the Environment.”13 Mark Chemaik is a toxicologist
and staff scientist with Environmental Law Alliance
Worldwide-US. His techno-legal opinions have been
relied upon by various courts around the world,
including the Supreme Court of India.
The sampling locations were tentatively identified
with the help of the scientists, and in collaboration
with local residents who mapped the lay of the land,
and identified key toxic hotspots such as hazardous
waste dumps, streams and drainage courses.
On 24 July, 2007, a total ofnine samples, including two
water, one effluent and six sediments, were collected.
[See Table No.4] The sampling was supervised by
Ruth Stringer to ensure compliance with Quality
Control and Quality Assurance measures. Details
such as sampling location, time of sampling, and other
observable conditions such as type of smell, texture
of sample at the time of sampling were recorded in
a “Sampling Sheet.”14 All samples were collected in
the presence of Mr. A. Marimuthu, Councillor of P.N.
Patti Town Panchayat Ward 1.
Samples were collected in specially prepared glass
bottles supplied by Specialty Analytical, an Oregon,
U.S.-based laboratory identified to perform the
analyses. The samples were transported to Chennai in
a cool box, packed with ice. In Chennai, each sample
bottle was repacked in bubble-wrap and replaced
in the cool box with ice. On 26th July, 2007, the
samples, along with the “chain of custody”15 forms,
were shipped to Specialty Analytical. The samples
were analysed for mercury using USEPA’s SW7471
method, for Volatile Organic Compounds by USEPA
SW8260B method, and for Semi Volatile Organic
Compounds using SW8270D.
Findings
The Report ofAnalyses from Specialty Analytical was
sent on 7 August, 2007. The Lab report in its entirety
is downloadable from the report section of
www.sipcotcuddalore.com
Effluent Sample being collected from “a pit on a road between
Chemplast Plant 2 and Plant 3”.
• A total of 52 chemicals were detected in the 9
samples, of which 17 chemicals were found above safe
levels. See Annexure 3 for complete list of chemicals
detected.
'inspection Report for Renewal of Consent Orders: Chemplast Sanmar Ltd. Plant III. District Environmental Engineer. Tamilnadu Pollution
Control Board. Salem. 14.3.06.
13 See Ruth Stringer and Paul Johnston, “Chlorine and the Environment. ” Kluwer Academic Publishers, 2001.
N See annexure 1
13 See annexure 2
1
Map of Mettur; Sampling Locations marked
METTUR
Coal ConvEYoR To MRtto
-
EFFLUENT SCREAM
SRiotiE
mm
Sampling locations
.QfOloS
SftNLEY
RESERVOIR
" (XoNUR PftNCHAYftT
___ cPe70R
fl
- PN PATTI PRNtHAYAT
£3
-
___ ,e.PO7o3
vEERRFAlPuoJR PANCHAYAT
iTuj
I^A«™RtPO70l(
IN®
lEffoR-
■CP070I
CP0705
^poiofc
E/f'wMOrt
Ch I - Chemplast plant I
Ch II - Chemplast plant II
rP»7o7
Ch HI - Chemplast plant ID
Ch V - Chemplast plant V
Th - Thermal power plant, MALCO
P - Karumalaikoodal police station
1-Tar & EDC waste dump site
2 - 23b tank, EDC storage
3 - EDC incinerator
4 - Oxychlorination Plant
5 - Sih from Effluent treatment plant
6 - Thermal power plant, Chemplast
7 - Hazardous waste over which thermal plant is built
8 - Mercury sludge
9 - Overhead pipeline carrying chlorine
10-Salt dump site
11 - Well contaminated by EDC commonly referred to as EDC well
12 - Salt contaminated land
13 - Salt contaminated land
14 - White formation on agricultural land; deposits from effluent stream
15 - Effluent pipeline from Chemplast plant 2 discharging into Kaveri
16 - Effluent pipeline from (Sfeplast plant 1 and 3 discharging into Kaveri
12
Table no.3: Chemicals Found Above Safe
Levels
Mercury
1,2,4-Trichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
Methylene Chloride
Bis(2-Ethylhexyl)PhthaIate
Hexachlorobenzene
Hexachlorobutadiene
Chloroform
Bis(2-chloroethyl)ether
Chlorobenzene
1,1,2-Trichloroethane
Ethylene Dichloride
Benzene
Vinyl Chloride
Tetrachloroethane
Trichloroethane
• Out of these 17 chemicals, 12 chemicals target
the eyes; 12 chemicals target the skin; 12 target the
liver; 3 chemicals target blood; 4 chemicals target the
cardio vascular system; 1 chemical targets the lung;
10 chemicals target the central nervous system; 12
chemicals target the respiratory system; 8 chemicals
target the kidneys; 1 chemical targets the lymphatic
system; 1 chemical targets the bone marrow; 2
chemicals target the reproductive system; 1 chemical
targets the gastrointestinal system; 1 chemical targets
the brain.
• 12 out of 17 chemicals are known to cause cancer
in humans or animals.
2. Environment Canada’s (Canadian environmental
regulatory agency) sediment quality criteria (assuming
that sediment contains a standard value of 1 % total
organic compounds).17
3. State of Washington sediment quality criteria
(assuming that sediment contains a standard value of
1 % total organic compounds).18
4. State of Wisconsin sediment quality standards.19
5. U.S. EPA water quality criteria for waters from
which fish is consumed.20
6. U.S. EPA drinking water quality criteria.21
7. World Health Organisation (WHO) drinking water
quality criteria.22
Discussion
Though recognized as highly toxic, India has not
evolved standards for many of the chemicals found.
Therefore, the results of analyses were compared
against seven sets of international health-based
standards by Dr. Mark Chemaik of ELAW-US.
Standards 1 to 4 were applied to Samples CP07001
to CP07006. Standard 5 was applied to Sample
CP07007. Standards 6 and 7 were applied to Samples
CP07008 to CP07009.
1. U.S. EPA sediment quality criteria (assuming
that sediment contains a standard value of 1 % total
organic compounds).16
Water sample being collected from borewell
belonging to G. Nallathambi
16 http://wyvw.epa.gov/yvaterscience/cs/report/2004/nsqs2ed-complete.pdf(assume sediment contains 1% total organic carbon)
17http://wwyv.elaov.org/assets/pdf/sediment%5Fsummary%5Ftable.pdf (assume sediment contains 1% total organic carbon)
'• http://www.ecy.wa.gov/programs/tcp/smu/sed_chem.htm (assume sediment contains 1% total organic carbon)
19 http://www.dnr.state.wi.us/org/aw/rr/technical/cbsqg_interim _final.pdf
10 http://yvyvw.elaw.org/assets/pdf/USEPAcriteria.pdf (Human health for consumption of organism only)
11 http://yvyvyv.elayv.org/assets/pdf/USEPAcriteria.pdf (Human health for consumption ofwater + organism)
11 http://yvyvyv.yvho.int/entity/yvater_sanitation_health/dyvq/gdyvq0506_ann4.pdf
i:
All samples of sediments contained mercury, pointing to the widespread contamination of the environment
with this toxic heavy metal. Additionally, in applying these criteria, the results show that EACH sample
contains unsafe levels of contamination in the following aspects:
Table4.1. Sediment sample from A dry storm water drain from Chemplast Plant 5”
Sample ID CP07001 A&B
Findings. 10 chemicals found, 1 chemical above health-based standard
Name
Value
Standard
Mercury mg/kg
0.989
Environment
Canada
No of times Carcinogen
above standard
No
5.8
Table 4.2: Sediment sample from “a dried up pond said to receive run-off from the salt
godown behind Plant 3”
Sample ID CP07002 A&B
Findings: 3 chemicals found; 1 chemical above health-based standard
Name
Mercury mg/kg
Value
Standard
1.54
Environment
Canada
No of times Carcinogen
above standard
9
No
Table 4.3: Sediment sample from “a pit on a road between Plant 2 and Plant 3, said
to be located adjacent and downgradient of a location where tarry wastes had been
dumped.”
Sample ID CP07003 A&B
Findings: 20 chemicals found; 3 chemicals above standards
Name
Value
ug/kg
Standard
No of times
above standard
Carcinogen
1,2,4-Trichlorobenzene
157
State of Wisconsin
20
No
1,2-Dichlorobenzene
490
Wisconsin
and
Washington State
21
No
1,4-Dichlorobenzene
652
Wisconsin
and
Washington State
21
Yes
Table 4.4: Sediment sample from “Storm drain between Plant 2 and plant 3”
Sample ID CP07004 A&B
Findings: 12 chemicals found; 4 chemicals above standards
14
Name
Value
Standard
No of times
above
standard
Carcinogen
Mercury mg/kg
34.90
190
No
Bis(2-ethylhexyl)
phthalate ug/kg
Hexachlorobenzene
ug/kg
Hexachlorobutadiene
ug/kg
1220
Environment
Canada
State of
Washington
2.6
Yes
819
State of
Washington
215
Yes
164
4.2
State of
Washington_____ _
Yes
Table 4.5: Sediment Sample from “Partially constructed sump in Bhupathy’s residence”
Sample ID CP07005 A&B
Findings: 1 chemical found; 1 chemical above standard
Name
Value
Standard
Mercury mg/kg
1.12
Environment
Canada
No of times
above standard
6.6
Carcinogen
No
Table 4.6: Sediment Sample from “Stormwater drain leaving plant 2 (PVC Plant)”
Sample ID CP07006 A&B
Findings: 29 chemicals found; 5 chemicals above standards
Carcinogen
No of times
above standard
1.9
No
161
No
60
No
67
Yes
5020
States of
Washington and
Wisconsin
States of
Washington and
Wisconsin
State of Washington
10
Yes
949
USEPA
1.15
No
Name
Value
Standard
Mercury mg/kg
0.332
1,2,4-Trichlorobenzene,
ug/kg
1,2-Dichlorobenzene,
ug/kg
1290
Environment
Canada
State of Wisconsin
1,4-Dichlorobenzene,
ug/kg
2080
Bis(2ethylhexyl)phthalate,
ug/kg
Chlorobenzene, ug/kg
1390
Table 4.7: Effluent Sample from “Piped effluent outfall from PVC Plant discharged
into the surplus course of River Kaveri”
Sample ID CP07007 A&B
Findings: 28 chemicals found; 6 chemicals above standards
1,2-dichloroethane
Value
ug/L
1260
Bis(2-chlorethyl)ether
136
1,1,2-Trichlorethane
50.50
1,2-Dichlorobenzene
2460
Benzene
14.6
Vinyl chloride
164
Name
Standard
World Health
Organisation
USEPA safety
standard for
consumption of fish
caught near pool
USEPA safety
standard for
consumption of fish
caught near pool
USEPA safety
standard for
consumption of fish
caught near pool
World Health
Organisation
World Health
Organisation
No of times
above standard
82
Carcinogen
257
Yes
3.15
Yes
65
No
1.5
Yes
546
Yes
Yes
1:
Table 4.8: Water Sample from “350-ft borewell on agricultural land belonging to S.
Chinnu, Thippampatti Kattuvalavu, Mettur.”
Sample ID CP07008 A&B
Findings: 7 chemicals found; 1 chemical above standard
Name
Benzene
Value
ug/L
7.76
No of times above
standard
USEPA for drinking 3.5
water
Standard
Carcinogen
Yes
Table 4.9: Water sample from “500 feet Borewell emptying into water tank belonging
to G. Nallathaiabi”
Sample 'ID CP07009 A&B
Findings: 10 chemicals found; 6 chemicals above standard
Name
1,1,2-Trichloroethane
Value
ug/L
33.60
Chloroform
10,100
Methylene chloride
1,140
Tetrachloroethane
55.60
Trichloroethane
22.20
Vinyl chloride
2.57
Standard
USEPA for drinking
water
USEPA for drinking
water
USEPA for drinking
water
USEPA for drinking
water
USEPA for drinking
water
USEPA for drinking
water
Yes
1771
No
248
Yes
327
Yes
38
No
8
Yes
Mercury dump site inside Chemplast Plant 3
16
Carcinogen
No of times
above standard
57
Diagram No. 2
Chemicals that target the various parts of the Human Body
1
Conclusion
the possible combined effect of long-term exposure
to a cocktail of 63 chemicals albeit at low concentrations
points to nothing less than a potential public health
disaster,” according to Dr. Rakhal Gaitonde, a public
health expert who reviewed the report. “Unless this
dangerous situation is addressed urgently, there is
potential for serious, unpredictable and potentially
irreversible consequences, as well as long term damage
The fact that the environment is contaminated by arange of to the environment, livelihoods, food and water security,”
cwjplex
and
highly
toxic
and
persistent he concludes.
chemicals, including mercury, organochlorines like
hexachlorobutadiene, hexachlorobenzene, and potential Recommendations
dioxins and furans qualifies categorization of Mettur
as a Toxic Hotspot. While this has huge environmental Based on the evidence generated by the current study,
consequences, there also is likely to be major detrimental and other studies to date, it would be prudent to apply the
effects on human health. These conclusions are based on precautionary principle in taking immediate steps to do
accepted knowledge about
the following:
these chemicals.
Evidence at hand indicates the extensive nature ofdamage
already caused. Tire continued discharge of toxic effluents
into the River Kaveri poses a risk to the drinking water
installations, to fish consumers to agricultural produce
consumers downstream. The indiscriminately disposed
toxic waste presents an ongoing source of groundwater
pollution.
Much of the damage done to Mettur’s environment may
well be irreversible. The Tamilnadu Pollution Control
Board and the District Administration have failed
miserably in administering their duties. Both agencies
seem to be subservient to the diktats of big polluters,
and are reluctant to implement the law. More curiously,
neither agency has sought to meet the residents and
understand their problems. The fact that the Police and
the District Administration continue to dismiss local
concerns about pollution as a law and order issue, and
continue to view complainants as extremists and trouble
makers bodes ill for the future of the environment in
Mettur and downstream of Kaveri. The evidence about
the contamination in Mettur is conclusive. All that
remains to be assessed is the extent of the damage already
done. The situation in Mettur is unlikely to change until
the TNPCB, the Police and the District Administration
begin viewing local people with more respect and free
themselves from the clutches of polluting industries.
It is not merely the presence of excessive levels of 17
toxic chemicals in the environment that should cause
concern. The fact that 52 chemicals, many of which have
known harmful effects, and may act synergistically to
create an even more poisonous cocktail is reason enough
to declare Mettur as a toxic hotspot. It is a known fact
that the toxicity of some chemicals multiplies several
fold when they act in conjunction with other chemical
agents.
1
18
“The widespread presence of excessive levels of at
least 17 chemicals with known harmful effects, and
1. End discharge of effluents into the River Kaveri
2. Conduct a comprehensive and independent assessment
of the spread and depth of contamination, including of
groundwater, water courses leading from the factory to
the River Kaveri, of environment and fish downstream of
Chemplast’s effluent discharge point, and of reservoir and
reservoir fisheries. The assessments should be conducted
with a particular focus on persistent, bioaccumultative
poisons such as dioxins and furans, and mercury.
3. Initiate a comprehensive clean-up involving local
communities.
4. Assess the impact of pollution on the health of people
in Mettur. Set up a long-term health monitoring and
remediation infrastructure to identify and assist affected
persons at the cost of the polluter.
5. Arrange for immediate delivery of clean water for
domestic purposes to affected communities and recover
costs from the polluter.
6. Initiate legal action and criminal prosecution
of polluter for negligent handling of chemicals
and
violation
of environmental
regulations.
7. Set up and enforce standards for organo-halogens
in various relevant media, including, soil, air, sediment,
effluents and water.
8. The Central Pollution Control Board should declare
Mettur a “Critically Polluted Area.”
9. The Kaveri Government Order prohibiting the
expansion or setting up ofnew polluting industries should
be implemented earnestly.
10. Strengthen public health systems to undertake
research and treatment of these pollution-related health
problems.
ANNEXURE 1
Toxicity Profiles of Key Chemicals 23
The 17 chemicals found above permissible limits are listed
below with their toxicological profiles.
Mercury:
Mercury is a naturally occurring silver-white, heavy,
odourless liquid metal. Mercury and its compounds
are widely distributed in the environment as a result
of both natural and synthetic processes. It is used in
the manufacture of thermometers and batteries, and
fluorescent lamps. However the largest consumer
of mercury is the chlor-alkali industry, which
manufactures caustic soda and chlorine. Workers
engaged in the chloralkali production are exposed to
high levels of elemental mercury.
Elemental mercury combines with other elements,
such as chlorine, sulphur, or oxygen, to form inorganic
mercury compounds or “salts.” Inorganic mercury
enters the air, water or soil from natural deposits,
disposal of wastes, from manufacturing plants and
volcanic activity. Mercury also combines with carbon
to form organic mercury compounds. Organic mercury
is more dangerous than inorganic forms, but many
inorganic mercury compounds can be converted to
the organic type in the environment.
Mercury is toxic to aquatic animals and is persistent
in the environment. Contaminated fish consumption
is the most common route of exposure to methyl
mercury, the most toxic form of mercury, in humans,
as it binds tightly to the proteins in fish tissue and also
accumulates as it passes through the food chain [see
diagram no.3]. In humans, it is absorbed readily into
the blood and distributed to all tissues including the
brain. It also readily passes through the placenta to
the foetus and foetal brain.
Acute exposure to toxic amounts of elemental
mercury can cause symptoms like vision and
hearing disturbance, dizziness, nausea, vomiting,
and respiratory problems. Long term exposure to the
various forms of mercury is known to cause emotional
disturbance, tremors, and other neurological problems,
dental problems, skin disorders and kidney injury.
Mercury is a potent neurotoxin and affects the central
nervous system causing irreversible damages.
Children exposed to mercury show symptoms of
mental retardation, sensory disturbances and neurobehavioral changes.
The fishing town of Minamata in Japan suffered a
severe methyl mercury poisoning incident during
the 1950s and 1960s. Mercury was discharged in
the Minamata Bay from a factory owned by Chisso
Corporation. Over years, the mercury accumulated in
fish was consumed by the local community. More than
20,000 people were reportedly affected by mercury
contamination.
A mother bathes her child; one of the many born with
severe birth defects known to be caused by exposure to
methyl mercury
1,2,4Trichlorobenzene:
Trichlorobenzene
1,2,4(1,2,4-TCB) is a synthetic
chemical that is an aromatic, colourless liquid. It is used
to make herbicides and other organic chemicals.
1,2,4Trichlorobenzene
evaporates slowly when
exposed to air. It mixes poorly in water. Once in air, it
breaks down to other chemicals. Unless it evaporates,
TCB is likely to stay in soil and water. Plants and
animals can store small amounts of TCB.
TCB enters the body when people breathe air or
consume contaminated food or water. It can also be
absorbed through skin contact. Once in the body small
amounts of TCB can remain, stored in fat tissue.
Short term effects of 1,2,4-TCB include changes in
liver, kidneys and adrenal glands. It also targets the
eyes, skin and respiratory system in humans.
33 For this section thefollowing sources have been extensively relied on.
Agencyfor Toxic Substances and Disease Registry, www.atsdr.cdc.gov/facts
U.S Environmental Protection Agency, www.epa.gov
Pocket Guide to Chemical hazards. US Department ofhealth and Human Services. February 2004
1,2Dichlorobenzene:
Dichlorobenzenes do not occur naturally. 1,2Dichlorobenzene is a colorless to pale yellow liquid
used to make herbicides. The substance decomposes
on burning producing toxic and corrosive gases
including hydrogen chloride. When released into
the environment, dichlorobenzenes bind to soil and
sediment. Dichlorobenzenes in soil usually are not
easily broken down by soil organisms. Evidence
suggests that plants and fish absorb dichlorobenzenes.
The substance is toxic to aquatic organisms.
Because of their relatively high lipid solubility and
relatively low water solubility, dichlorobenzenes are
likely to be absorbed by most routes of exposure by
membrane diffusion.
(cirrhosis). The International Agency for Research on
Cancer (IARC) detennined that 1,4-Dichlorobenzene
is possibly carcinogenic to humans.
The presence of high levels of dichlorobenzenes
is used as an indicator for the likely presence of
dioxins.
Bis(2-Ethylhexyl)phthalate (carcinogen):
Bis(2-ethylhexyl)phthlate (DEHP) is a manufactured
chemical that is commonly added to plastics to make
them flexible. It is a colorless liquid with almost
no odor. DEHP can enter the environment through
releases from factories that make or use DEHP.
Over long periods of time, it can move out of plastic
materials into the environment. When DEHP is
Inhaling the vapor or dusts of 1,2-DCB and 1,4-DCB released to soil, it usually attaches strongly to the soil
at very high concentrations can cause irritation of and does not move very far from where it was released.
the eyes and nose, burning and tearing of the eyes, When DEHP is released to water, it dissolves very
coughing, difficult breathing, and an upset stomach. slowly into underground water or surface waters that
The substance may also affect the central nervous contact it. DEHP is everywhere in the environment
system. Human toxicity data for 1,2-dichlorobenzene because of its use in plastics. One can be exposed to
is sparse but chromosomal aberrations, anemia and DEHP through air, water, or skin contact with plastics
leukemia have been reported. It is also found to be
that have DEHP in them.
toxic to higher plants. Long term exposure targets the
liver and kidneys. It has also been described to defat
Acute exposure to large oral doses of DEHP can
(remove fat) the skin after long term and repeated
cause gastrointestinal distress in humans. It affects
exposure.
the reproductive system and liver. The International
Agency for Research on Cancer has classified Bis (21,4Dichlorobenzene
(carcinogen):
DichIorobenzene
1,4occurs as colorless or white ethylhexyl) phthalate as Group 2B: Possible human
solid with a distinctive aromatic odour, similar to carcinogen (IARC, 1987).
mothballs. It is practically insoluble in water. When it
is heated, toxic gases and vapors such as hydrochloric
acid and carbon monoxide are released.
For the past 20 years 1,4-dichlorobenzene has been
used primarily as a deodorant in products such as
room deodorizers, urinal and toilet bowl blocks, and
as an insecticide fumigant for moth control. 1,4Dichlorobenzene has been detected in meats and eggs
following exposure of the animals and in fish from
contaminated waters.
Dichlorobenzene
1,4may be absorbed both through
the inhalation of vapours, through the skin and through
consumption of contaminated food. Once absorbed
dichlorobenzene
1,4is stored in fatty tissue.
20
Dizziness and headaches can occur due to very high
levels of 1,4-DCB. Other symptoms include damage
to the kidneys and lungs. It is known to cause eating
disorders (anorexia), jaundice and liver disorder
Hexachlorobenzene (carcinogen):
Hexachlorobenzene is a white crystalline solid that is
not very soluble in water. It does not occur naturally
in the environment. It is formed as a by-product while
making other chemicals, in the waste streams of
chloralkali, and when burning municipal waste.
HCB is a persistent chemical and is widely distributed
throughout the environment because it may be
carried in the air on dust particles and is resistant to
degradation. Hexachlorobenzene can enter your body
when you eat food contaminated with it, when you
breathe particles of it in the air, or when it gets on your
skin. A large portion of hexachlorobenzene in the fat
of a mother can be transferred to her baby in breast
milk. During pregnancy, this substance can transfer to
the unborn child through the mother’s blood.
HCB is toxic to aquatic life, plants, animals and
humans. It is classified as a possible human carcinogen
and tumour promoter by the International Agency for
Research on Cancer (IARC). HCB is toxic at very Bis (2-chloroethyl)ether (carcinogen):
low concentrations and doses with chronic exposures. Bis(2-chloroethyl)ether isacolourless, non-flammable
HCB damages the developing foetus, liver, immune liquid with a strong unpleasant odor. It does not occur
system, thyroid, kidneys and central nervous system. naturally. Bis(2-chloroethyl) is made in factories,
The liver and nervous system are the most sensitive and most of it is used to make pesticides. Some of it
to its effects. Porphyria a liver disorder characterised is used as a solvent, cleaner, component of paint and
by red-colored urine, skin sores, change in skin color, varnish, or as a chemical intermediate to make other
arthritis, and problems of the liver, nervous system, chemicals.
and stomach is a common symptom of HCB.
Breathing low concentrations of bis(2-chloroethyl)
More than 600 people in Turkey experienced severe ether will cause coughing, and irritation to nose,
skin disorders (porphyria) after consuming HCB- eyes, skin, throat and lungs. In some cases, damage
treated grain between 1955 and 1959. Children bom to the lungs can be severe enough to cause death. The
to women exposed to this chemical had skin lesions USEPA has classified this chemical as a Group B2,
and 95% of them died before their first birthday.24
probable human carcinogen.
Hexachlorobutadiene (HCBD) (carcinogen):
Chlorobenzene:
HCBD isacolourless liquid with a turpentine likeodour.
It is produced either commercially or as a by-product
of manufacturing other chlorinated hydrocarbons
including
Tetrachloroethene,
Trichloroethene,
VCM/PVC, and Carbon Tetra Chloride. HCBD is a
widespread environmental contaminant. HCBD is an
indicator of the presence of even more toxic chemicals
such as dioxins and furans
Chlorobenzene is a colourless, flammable liquid
with an aromatic, almond-like odor. It does not occur
naturally in the environment. The greatest use of
chlorobenzene is in the manufacture of other organic
chemicals, dyestuffs and insecticides. It is also a
solvent for adhesives, drugs, rubber, paints and dry
cleaning.
Hexachlorobutadiene is released to the environment
in air, water, and soil, mainly as a result of its disposal
following industrial use. It can exist in the atmosphere
as a vapour or absorbed to airborne particulate
matter. It has been found in the wastewater from
the chlorine industry, in leachate from landfills and
hazardous waste sites and in air, soil, surface water
and sediments. It is toxic to aquatic organisms. It also
bioaccumulates in the food chain, especially in the
fish. One may be exposed to hexachlorobutadiene by
breathing contaminated air, eating contaminated food,
drinking contaminated water, or by direct skin contact
with this chemical.
If ingested HCBD concentrates in the kidney, the main
target organ. HCBD interferes with the fundamental
process of cell respiration and can, as a result or along
with other compounds in the body, react with DNA,
resulting in cell death or the development of tumours.
It is also known to cause damage to the liver. HCBD
is classified as a potential occupational carcinogen
by the USEPA and it also causes kidney tumours in
animals.
Stringer and Paul Johnston. ■ Chlorine and the Environment." Kluwer A.
Chlorobenzene enters your body through air,
ingestion of food or water, or through contact with
the skin. In animals, exposure to high concentrations
of chlorobenzene affects the brain, liver, and kidneys.
Workers exposed to high levels of chlorobenzene
complained of headaches, numbness, sleepiness,
nausea, and vomiting. Chlorobenzene has the potential
to cause liver, kidney and central nervous system
damage from long term exposure. Effects on the
central nervous system from breathing chlorobenzene
include loss of consciousness, tremors, restlessness,
and death.
1,1,2Trichloroethane
(carcinogen):
1,1,2Trichloroethane
is a colorless, sweet-smelling
liquid. 1,1,2-Trichloroethane is not known to occur
as a natural product, It is used to make vinylidene
chloride which is in turn used to make synthetic
fibers and plastic wraps such as the saran wrap. 1,1,2Trichloroethane is sometimes present as an impurity
in other chemicals, and it may be formed when
another chemical breaks down in the environment
Most
1,1,2-trichloroethane released into the
environment will go into the air and it breaks down
slowly in air. 1,1,2-Trichloroethane may enter the
groundwater by filtering through the soil and also
appears to stay in water for a long time; it takes years
for it to break down.
Breathing outdoor air that contains it from industrial
releases or air near hazardous waste site, drinking
contaminated water are the common routes of
exposure, to 3,1,2-trichloroethane.
’Physical contact with 1,1,2-trichloroethane can result
m stinging and burning of the skin. Acute animal
studies have reported effects on the liver, kidney, and
central nervous system (CNS) from inhalation and
oral exposure to 1,1,2-trichloroethane, while chronic
animal studies have reported effects on the liver and
immune system from oral exposure. USEPA has
classified 1,1,2-trichloroethane as a Group C possible
human carcinogen.
Ethylene Dichloride (carcinogen):
headache, nausea, sore throat etc.
It is distributed to all tissues of the body and can pass
both the blood/brain barrier and the placenta. EDC is
classified by the International Agency for Research on
Cancer (IARC) in Group 2B (possibly carcinogenic
to humans) and can be toxic at concentrations too low
to be detected by smell. In animals it causes cancer of
stomach, mammary gland and blood.
Benzene (carcinogen):
Benzene is a colorless liquid with a sweet odor. It
evaporates into the air very quickly and dissolves
slightly in water. It is highly flammable and is formed
from both natural processes and human activities.
Some industries use benzene to make other chemicals
which are used to make plastics, resins, and nylon and
synthetic fibers. It is also used to make some types
of rubbers, lubricants, dyes, detergents, drags, and
pesticides. Industrial processes are the main source
of benzene in the environment. It breaks down more
slowly in water and soil, and can pass through the soil
into underground water. Natural sources of benzene,
which include gas emissions from volcanoes and
forest fires, also contribute to the presence of benzene
in the environment. Benzene is also present in crude
oil and gasoline and cigarette smoke.
Ethylene Dichloride (EDC) is amanufactured chemical
that is not found naturally in the environment. It is
primarily used in the manufacture of Vinyl Chloride
Monomer - the building block for PVC. It is both an
intermediate in the manufacture of PVC and a pollutant
released from PVC facilities in large quantities. It Breathing very high levels of benzene can result
in death, while high levels can cause drowsiness,
is a pleasant-smelling, colourless, volatile liquid,
which does not persist long in the environment but is dizziness, rapid heart rate, headaches, tremors,
confusion, and unconsciousness. Eating or drinking
both hazardous and toxic. It decomposes on heating
foods containing high levels of benzene can cause
and on burning, producing toxic and corrosive
vomiting, irritation of the stomach, dizziness,
fumes including hydrogen chloride and phosgene.
sleepiness, convulsions, rapid heart rate, and death.
An explosive accident involving EDC can result
in Bhopal-like disasters because of the tendency of
explosion by-products like hydrogen chloride and The major effect of benzene from long-term exposure
is on the blood. Benzene causes harmful effects on the
pttosg^ae to form clouds and spread far and wide.
bone marrow and can cause a decrease in red blood
Once released in the environment, EDC volatilises cells leading to anemia. It can also cause excessive
into the air. lit is not absorbed into the soil but it leaches bleeding and can affect the immune system, increasing
through the soil to the groundwater where it remains the chance for infection. Some women who breathed
high levels of benzene for many months had irregular
for a longer time, thus contaminating the water.
menstrual periods and a decrease in the size of their
Because of its volatility the prime route of exposure is ovaries. Benzene is a known human carcinogen (Group
through inhalation. However, it can also cause harm 1 as assessed by IARC) and has been associated with
through skin or eye contact. It causes irritation of the leukemia.
22
eyes, the skin and the respiratory tract. Inhalation
of the vapour may cause lung oedema - a condition
where the lung fills up with fluid. EDC also impairs
the functioning of the central nervous system, kidneys
and liver. Other symptoms of exposure include
- abdominal pain, cough, dizziness, drowsiness,
Vinyl Chloride (carcinogen):
Vinyl Chloride, a synthetic chemical is both an
intermediate in the manufacture of PVC and a pollutant
released from PVC facilities in large quantities. VCM
is a colourless sweet smelling gas under normal
conditions. Most of the vinyl chloride that enters the
environment comes from vinyl chloride manufacturing
or processing plants, which release it into the air or
into waste water. Breathing vinyl chloride that has
been released from plastics industries, hazardous
waste sites, and landfills, breathing vinyl chloride
in air or during contact with your skin or eyes in the
workplace and drinking water from contaminated
wells are the common routes of exposure in humans.
Inhalation of vinyl chloride can cause dizziness,
headaches, drowsiness or unconsciousness, memory
loss, sleep disturbances, and nervousness. Inhaling
large amounts of Vinyl Chloride may even cause
death. Vinyl Chloride is known to cause lung related
problems. It also affects the immune systems, liver,
spleen, thyroid functions, and reproductive system
in both men and women. Vinyl Chloride also causes
changes in the blood flow to the hands. It is a known
human carcinogen (Group 1 as assessed by IARC).
Studies demonstrate that it causes malignant tumour
of the liver in the occupationally exposed; other
studies have also shown elevated levels of cancer of
brain and nervous system, lung and respiratory tract
and the lymphatic system.
Chloroform (carcinogen):
Chloroform is a heavy, colourless, non-flammable
liquid with a sweetish burning taste and a pleasant,
sweet, ethereal odour. It is a naturally-occurring
chemical, but mostofthe chloroform in the environment
is man-made. It was used as an anaesthetic in the past,
but the US Food and Drug Administration banned its
use in 1976 after it was found that chloroform is a
potential carcinogen. Most of the chloroform released
in air breaks down eventually, but it is a slow process.
The breakdown products in air include phosgene
and hydrogen chloride, which are both toxic. It is
poorly absorbed in the soil and can travel through
soil to ground water where it may persist for years. It
dissolves easily in water where it may break down to
form other chemicals. It is extremely toxic to aquatic
animals.
One is most likely to be exposed to chloroform by
drinking water and breathing indoor or outdoor air
containing it.
Exposure to chloroform may cause irritation of eyes,
skin, dizziness, mental dullness, nausea, confusion,
headache, weakness, exhaustion, and enlarged
liver. Chloroform is also a potential occupational
carcinogen and causes cancer of liver, kidney and
intestine in animals. It has also shown to cause
reproductive damage in lab animals. USEPA has
classified chloroform as a Group 2B, probable human
carcinogen.
Methylene Chloride (carcinogen):
Methylene Chloride is a colourless liquid with
chloroform like odour which does not occur naturally
in the environment. Methylene chloride is mainly
released to the environment in air. It does not easily
dissolve in water, but small amounts may be found in
drinking water. Methylene chloride is mainly released
to the environment in air, and to a lesser extent in
water and soil, due to industrial and consumer uses.
Methylene chloride is poorly absorbed in the soil but
can travel through soil to ground water where it may
persist for years.
Methylene chloride may enter your body when you
breathe in contaminated air. It may also enter your
body if you drink water from contaminated wells, or
it may enter if your skin comes in contact with it.
Exposure to Methylene Chloride may cause irritation
eyes, skin, weakness, exhaustion, drowsiness,
dizziness, numbness, a tingling sensation in the
limbs, and nausea. Methylene chloride is a potential
occupational carcinogen and causes cancer in the
lungs and liver of animals. Exposure to high levels of
methylene chloride may cause unconsciousness and
even death.
Tetrachloroethane (carcinogen):
Tetrachloroethane
1,1,2,2is
a
manufactured,
colourless, dense liquid that does not bum easily. It
is volatile and has a sweet odor. Tetrachloroethane is
one of the most toxic chlorinated hydrocarbons.
Most 1,1,2,2-tetrachloroethane released into the
environment eventually moves into the air or
groundwater. If released on the land, it does not tend to
attach to soil particles. 1,1,2,2-Tetrachloroethane can
enter the body when a person breathes air containing
the chemical or when the chemical comes into contact
with a person’s skin. Acute exposure to concentrated
fumes can rapidly cause fatigue, vomiting, dizziness,
and possibly unconsciousness. Breathing, drinking,
or having 1,1,2,2-tetrachloroethane come into
contact with your skin may cause liver damage,
stomachaches, or dizziness if you are exposed long
enough to high amounts. The USEPA has classified
tetrachloroethane
1,1,2,2as a Group C possible
human carcinogen.
Trichloroethane:
1,1,1-Trichloroethane is a synthetic Chemical.
Manufacture of this chemical for domestic use
in the United States was banned as of January 1,
2002 because it affects the ozone layer. Most of the
1,1,1-trichloroethane released into the environment
enters the air, where it lasts for about 6 years. 1,1,1Trichloroethane has many industrial and household
uses, including use as a solvent to dissolve other
substances, such as glues and paints; to remove oil or
grease from manufactured metal parts; and as an in
gradient of household products such as spot cleaners,
glues., and aerosol sprays.
Once in the air, it can travel to the ozone layer where
sunlight can break it down into chemicals that may
reduce the ozone layer. Contaminated water from
landfills and hazardous waste sites can contaminate
surrounding soil and nearby surface water or
groundwater.
Breathing 1,1,1-trichloroethane in contaminated
outdoor and indoor air is the most common route of
exposure in humans. Because 1,1,1 trichloroethane is
used so frequently in home and office products, one
is likely to be exposed to higher levels indoors than
outdoors or near hazardous waste sites.
Effects reported in humans due to acute (short
term) inhalation exposure to trichloroethane include
hypotension, mild hepatic effects, and central nervous
system(CNS)depression. Symptomsofacuteinhalation
exposure include dizziness, nausea, vomiting, diarrhea,
loss of consciousness, and decreased blood pressure
in humans. Studies in animals show that breathing air
that contains very high levels of 1,1,1- trichloroethane
damages the breathing passages and causes mild
effects in the liver, in addition to affecting the nervous
system.
Dioxins and furans:
These are formed as an unintentional by-product
of industrial processes involving chlorine, and are
especially linked to the production of Poly Vinyl
Chloride, which is also known as the Poison Plastic.
High doses of dioxin cause a severe skin disease called
chloracne. Dioxin exposure has also been linked to
cancer, suppressed immune system, severe reproductive
problems,
developmental problems, hormonal
problems, inability to maintain pregnancy, decreased
fertility, reduced sperm counts, endometriosis, diabetes,
learning disabilities, lung problems, skin disorders,
lowered testosterone levels and much more.
Persistent Organic Pollutants
Dioxins/furans and Hexachlorobenzene are classified as Persistent Organic Pollutants (POPs),
and are slotted for global phase-out under the international Stockholm Convention on POPs. All
POPs exhibit certain key characteristics, and are considered extremely dangerous. The charac
teristics include:
Persistence: Once released into the environment, they bind strongly to the soil and remain
there for long periods of time without being broken down.
Fat-loving: All POPs have an affinity to fatty substances. That is why they are found in largest
quantities in the fatty tissue of living organisms.
Bioaccumulation: Because they are fat-soluble and resist natural breakdown processes, POPs
tend to build up (bioaccumulate) in the fatty tissues of animals and humans.
Biomagnification: For many POPs, the levels increase as one animal eats another lower on the
food chain. The highest levels are found in predators at the top of food chains such as humans,
birds of prey and predatory fish.
Transgenerational Poisons: POPs are transferred from mother to offspring through the pla
centa, or via breast milk. Exposure at these early stages of life is especially dangerous because
this is the time when the body’s systems and organs are developing. Chemicals such as dioxins
can significantly alter the course of a foetus or child’s development.
Toxicity: Even at very low concentrations, sometimes not measurable, POPs have the potential
to harm human and animal health. Many of these effects are irreversible. Pre-birth effects of
these chemicals include malformations, neurological effects and changes to the immune system
giving rise to cancer or infections.
24
Mercury and Dioxin Cycle; in the environment
Diagram No.3
Annexure 2
Sample Sheet
Sample ID.-
Type of Sample: water/ sediment/ effluent/ other (please descreibe)
Location:
Address of sample location (include city, State, and Country)
Name and type on industry —
(for industrial samples)
Description of location Coordinates —
Description of sample:
Odour —
Colour —
Suspended Solids Visible oil or grease —
Temperature (can be approximate) Other -
Any other comments about location or the nature of the sample:
Description of the tests to be conducted on the sample:
VOCsSVOCs PCDD/Fs HgMeHg —
Other -
Date:
Time:
Name of the sampler:
Signature of the sampler:
Sampled in the presence of:
26
Annexure 3
Chain of Custody
CHAIN OF CUSTODY RECORD
to
. i
00
Annexure 4
List of all Chemicals detected in the 9 samples
S.No
Chemical
CP07001
CP07002
CP07003
CP07004
CP07005
CP07006
1
*
Mercury
0.989 mg/kg
1.54 mg/kg
0.121 mg/kg
34.9 mg/kg
0.332 mg/kg
1.12 mg/kg
2
Benz(a)anthracene
59.0 ug/kg
3
Benzo(a)pyrene
59.7 ug/kg
4
Benzo(b)fiuoranthene
114 ug/kg
60 ug/kg
48.3 ug/kg
5
*
Bis(2-ethylhexl)phthalate
496 ug/kg
1220 ug/kg
5020 ug/kg
6
Chrysene
51.7 ug/kg
7
Dimethyl Phthalate
144 ug/kg
46 ug/kg
8
Fluoranthene
116 ug/kg
60.3 ug/kg
9
Phenanthrene
53.7 ug/kg
10
Pyrene
99.3 ug/kg
11
3-&4-Methyphenol
676 ug/kg
12
Phenol
70.7 ug/kg
13
1,2,4*Trichlorobenzene
14
1,2*
Dichlorobenzene
CP07007
52 ug/kg
40.3 ug/kg
42.3 ug/kg
44.3 ug/kg
576 ug/kg
1.37 ug/L
S“
157 ug/kg
1290 ug/kg
V
122 ug/kg
90.8 ug/kg
149 ug/kg
1390 ug/kg
6.91 ug/L
490 ug/kg
474 ug/kg
11.7 ug/L
S
V
15
Trichloroethane
16
*
Bis(2-Chloroethyl)ether
CP07008
3.31 ug/L
625 ug/kg
712 ug/kg
136 ug/L
4.91 ug/L
CP07009
17
1,2,3-Trichlorobenzene
32.8 ug/kg
18
*
1,2-Dichloroethane
57.6 ug/kg
150 ug/kg
2460 ug/L
19
1,2-Dichloropropane
59.5 ug/kg
10.1 ug/kg
13.8 ug/L
20
1,3-Dichlorobenzene
S
V
21
1,3-Dichloropropane
22
1,4-Dichlorobenzene
*
208 ug/kg
20.3 ug/kg
37 ug/kg
16.9 ug/kg
17.3 ug/kg
2.19 ug/L
S
199 ug/kg
2080 ug/kg
8.45 ug/kg
V
652 ug/kg
665 ug/kg
14.8 ug/L
5.93 ug/L
1.62 ug/L
1.07 ug/L
23
2-Butanone
131 ug/kg
24
2-Chlorotoulene
19.8 ug/kg
37.4 ug/kg
25
4-Chlorotoulene
10.1 ug/kg
17.4 ug/kg
26
*
Benzene
17.5 ug/kg
55.5 ug/kg
14.6 ug/L
7.76 ug/L
27
*
Chlorobenzene
521 ug/kg
949 ug/kg
48.6 ug/L
34.8 ug/L
28
Naphthalene
241 ug/kg
1.85 ug/L
S
V
23.4 ug/kg
19.6 ug/kg
23.1 ug/kg
14.2 ug/kg
29
Vinyl Chloride
*
30
Di-N-Butyl Phthalate
44.7 ug/kg
31
*
Hexachlorobenzene
819 ug/kg
32
*
Hexachlorobutadiene
164 ug/kg
33
Hexachloroethane
480 ug/kg
34
Pentachlorophenol
123 ug/kg
34.7 ug/kg
164 ug/L
2.57 ug/L
LU
O
F35
Toulene
26.9 ug/kg
1.35 ug/L
1.56 ug/L
98.3
%REC__
36
2-Methylnaphthalene
50 ug/kg
37
1,1-Dichloroethane
53 ug/kg
38
1,1,2-Trichloroethane
*
**
50.5 ug/L
39
1,2,3-Trichloropropane
2.74 ug/L
40
Bromochloromethane
2.90 ug/L
41
Bromodichloromethane
2.43 ug/L
42
Bromoform
30.6 ug/L
43
*
Chloroform
252 ug/L
44
Chlbromethane
2.734ug/L
45
cis-1,2-Dichloroethene
15.7 ug/L
46
•
Dibromochloromethane
12.2 ug/L
47
Dibromomethane
10.2 ug/L
48
Trans-1,2-Dichloroethane
8.37 ug/L
49
1,1-Dichloroethene
1.39 ug/L
50
Methylene Chloride
*
1140 ug/L
51
*
Tetrachloroethene
55.6 ug/L
52
*
Trichloroethene
22.2 ug/L
44.3 ug/L
4.39 ug/L
1.51 ug/L
33.6 ug/L
1.93 ug/L
10100
_ug/l----------
*Chemicals found at levels above the permissible limit
** S-Semivolatile, V-Volatile
4.08 ug/L
Annexure 5
Pace Analytical Services. Inc.
1700 Elm Street - Suite 200
Minneapolis. MN 55414
m
Tel: 612-607-1700
Method 8290 Sample Analysis Results
Client - Specialty Analytical
Client's Sample ID
Lab Sample ID
Filename
Injected By
Total Amount Extracted
% Moisture
Dry Weight Extracted
(CAL Date
CCal Filename(s)
Method Blank ID
0710092-01
1061251001
U71107B 10
SMT
12.5 g
20.0
10.0 g
09/27/2007
U71107B 02 & U71107B 18
BLANK-14615
RL
Native
Isomers
Cone
ng/Kg
EMPC
ng/Kg
ng/Kg
2,3,7,8-TCDF
Total TCDF
4.90
40.00
----—
0.26 A
0.26
2,3,7,8-TCDD
Total TCDD
0.33
2.90
---------
0.22 JA
0.22
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
Total PeCDF
6.20
5.40
35.00
-------------
1.00
1.00
1.00
1,2,3,7,8-PeCDD
Total PeCDD
ND
ND
---------
1.00
1.00
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
Total HxCDF
---6.30
3.50
3.30
39.00
21.0
-----------------
1.00 E
1.00
1.00 J
1.00 J
1.00
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8.9-HxCDD
Total HxCDD
ND
----ND
ND
----2.2
---------
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
Total HpCDF
60.00
11.00
130.00
1,2,3,4,6,7,8-HpCDD
Total HpCDD
OCDF
OCDD
_
___
Matrix
Dilution
Collected
Received
Extracted
Analyzed
Soil
NA
07/24/2007
10/18/2007
10/29/2007
11/07/2007 16:56
Internal
Standards
ng’s
Added
Percent
Recovery
2,3,7,8-TCDF-13C
2,3,7,8-TCDD-13C
1,2,3,7,8-PeCDF-13C
2,3,4,7,8-PeCDF-13C
1,2,3,7,8-PeCDD-13C
1,2,3,4,7,8-HxCDF-13C
1,2,3,6,7,8-HxCDF-13C
2,3.4,6.7,8-HxCDF-13C
1,2,3,7,8,9-HxCDF-13C
1,2,3,4,7,8-HxCDD-13C
1,2,3,6,7,8-HxCDD-13C
1,2,3,4,6,7,8-HpCDF-13C
1,2,3,4,7,8,9-HpCDF-13C
1,2,3,4,6,7,8-HpCDD-13C
OCDD-13C
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
4.00
1.2.3.4-TCDD-13C
1,2,3,7,8,9-HxCDD-13C
2.00
2.00
NA
NA
1.90 A
2.00 IA
1.10 A
1.70
2,3,7,8-TCDD-37CI4
0.20
80
-------------
1.00
1.00
1.00
Total 2,3,7,8-TCDD
Equivalence: 6.7 ng/Kg
(Using ITE Factors)
----ND
44.0
----
1.40 IA
1.40
460.00
380,00
---------
2.00
2.00
Cone = Concentration (Totals include 2.3.7.8-substituted isomers).
EMPC = Estimated Maximum Possible Concentration
RL = Reporting Limit.
ND = Not Detected
NA = Not Applicable
NC = Not Calculated
Results reported on a dry weight basis and are valid to no more than 2 significant figures.
J = Value below calibration range
A = Reporting Limit based on signal to noise
E = PCDE Interference
I = Interference present
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full.
without the written consent of Pace Analytical Services. Inc.
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69
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