LETTER TO EPA ABOUT CHEMICAL RELEASE

February 28, 1996
To: Lauren Volpini
USEPA
EPCRA & CERCLA Enforcement
75 Hawthorne Street
San Francisco, CA 94105-3901
From:Don't Waste Arizona, Inc. &
Concerned Residents of South Phoenix
6205 S. 12th Street
Phoenix, AZ 85040
(602) 268-6110
fax = (602) 268-0915

Please review the following information pertaining to a CERCLA and EPCRA Section 304 release that was not properly reported as these laws require. The incident in question is the Quality Printed Circuits (QPC) toxic fire on August 31, 1992. A chemical inventory of what was burned in the fire was compiled for QPC by Industrial Compliance, 9830 South 51st Street, Phoenix, AZ 85044, (602) 496-4100, is attached. The Tier Two Reports filed by QPC available at the AERC collaborate the amounts on-site at the fire event. Current contamination in homes is well documented, as well as the lingering illness of hundreds and a continued increased mortality rate in the affected census tract.

RQ is the amount that must be released before the National Response Center must be notified and a report produced for the community about health effects.

CAS # ChemicalAmountRQ
7664-93-9 Sulfuric Acid9,377.73 lbs 1,000 lb RQ
7664-41-7Ammonia717 lbs 100 lb RQ
7697-37-2Nitric Acid 633.60 lbs1,000 lb RQ
7664-39-3Hydrogen Fluoride 639.74 lbs100 lb RQ
50-00-0Formaldehyde 216.47 lbs100 lb RQ
1310-73-2Sodium Hydroxide 1666 lbs1,000 lb RQ


The following is a more detailed description of the calculations for each chemical. The information for each of these calculations was derived from an inventory list compiled by Industrial Compliance, which was hired by Quality Printed Circuits (QPC) to inventory what was burned in the fire and what was removed after the fire. This report was presented to the Arizona Department of Environmental Quality (ADEQ). The amounts in the report are in gallons. The conversions and calculations are as follows:

Sulfuric Acid
Straight forward calculation from MSDS in QPC file at the AERC 660 gallons in fire specific gravity = 1.842 660 gal X 14.736 lb/gal = 9725.76 lbs X.96% by weight = 9336.73 lbs add 41 lbs from page 9 = 9377.73

Ammonia
A variety of products list ammonia as a decomposition product. The smell of ammonia was prevalent during the fire event and is so stated in the fire report. The MSDSs for these chemical mixtures were not in the AERC file. A conservative weight of Ammonia is that for Anhydrous Ammonia with a specific gravity of.68 = 5.44 lb/gal. For the Ultra Etch 50 a conservative figure of 21% was used. 440 gallons were in the fire. 440 gal X.2125 = 93.5 gal X 5.44 lb/gal = 508.64 lbs. Similar calculations were used for the products by evenly dividing the decomposition products. These calculations need a chemist's review. However, with the total of 717 lbs and the documented reports of ammonia vapors, a release of over 100 lbs most certainly occurred.

Nitric Acid
This is a straight forward calculation from the MSDS in the QPC file at the AERC. A mid-point of.625% was used. Specific gravity = 1.408. 90 gallons X.625 = 56.25 gallons X 11.264 lb/gal = 633.60 lbs. On page 16 the ³in process quantity in fire² was cut off. Only 34 more gallons are needed for a violation. You need to request from Industrial Compliance (9830 S. 51 Street, Phoenix, AZ, 85040 telephone = (602) 496-4100) the entire page 16 of the review of the Quality Printed Circuits fire of August 31, 1992.

Hydrogen Fluoride
The decomposition products of Fluoboric Acid are Hydrogen Fluoride (HF) and Oxides of Boron. The molecular weight of these two decomposition products are nearly the same. However a conservative figure of.4 instead of.5 was used. 350 gallons in fire X 48% Fluoboric Acid = 168 gallons X.4 HF of acid = 67.2 gal X 9.52 lb/gal = 639.74 lbs HF. (Specific gravity = 1.19)

Formaldehyde
This is a straight forward calculation from the MSDS in the QPC file at the AERC. A midpoint of 37.5% was used in one formula and 5.5% in another formula. Specific Gravity = 1.09. 42 gallons X.375 = 15.75 gal X 8.72 lb/gal = 137.34 lbs. Also, 165 gallons X.055 = 9.075 gal X 8.72 lb/gal = 79.13 lbs. Total = 216.47 lbs.

Sodium Hydroxide
This is a straight forward calculation from the MSDS in the QPC file at the AERC. Specific gravity = 1.525. A total of 1000 lbs X 99% = 990 lbs plus 220 gallons X 25% (midpoint) = 55 gallons X 12.2 lb/gal = 671 lbs. Plus another five pounds from the M-Copper 853. Total = 1666 lbs.

SIGNIFICANT DIFFERENCES IN SAMPLING METHODS AND RESULTS

In October 1992, May 1993, and January 1994, the Arizona Department of Environmental Quality (ADEQ) conducted sampling of study homes in the area where the plume of smoke passed during the 1992 fire at Quality Printed Circuits. The problem with the ADEQ sampling was that there was never a study of homes outside the area affected by the fire to see what chemicals normal homes, called control homes, have in them. In May and June 1997, the Environmental Protection Agency (EPA) conducted sampling of 34 study homes in the affected area and five control homes outside the affected area. The sampling plan was reviewed and suggestions on the sampling and the data that might result were made by Technical Outreach Services for Communities (TOSC) of Oregon State University. [For more on TOSC, refer to the article on TOSC in this newsletter.]

(Contaminants found at levels that were statistically higher in study homes as compared to control homes.)

COMPARISON OF EPA AND ADEQ SAMPLING RESULTS
MEDIAEPA RESULTS ADEQ RESULTS
Ventilation DuctsCopper
Boron
Fluoride
Tin
PAHs		Copper
Zinc
Fluoride
House DustBoron
Lead
Nickel
Nitrate		Copper
Lead
Nickel
Zinc
Outdoor Soil Boron
Copper
Lead
Zinc
Chloride
PAHs*		Nothing

FROM THE EDITOR

This is our first edition, and because there is so much information to tell from a period of so much time, it is a large edition, probably triple the size our future, regular editions will be. There will be several more editions of this Environmental Justice newsletter during the period of the EPA Environmental Justice small grant. The Concerned Residents of South Phoenix and Don't Waste Arizona, Inc. have never had the resources before this to get the word out to the entire community about all of this, but thanks to this EPA small grant, we now have the opportunity. People often ask us how come they were not personally contacted, mailed, or somehow given the latest information. The reality is that no one ordinarily or automatically has the resources to do this sort of thing. This sort of chemical fire disaster does not happen often, fortunately, so no one really ever plans for that to happen. The EPA has recognized that this special need for this sort of communication in this community is an Environmental Justice consideration, and EPA has provided the funds. Several local non-profit organizations are assisting in the newsletter's distribution. We plan to publish and distribute our next edition shortly after Christmas. If there is some significant new development or a special need, we will publish sooner. The results of EPA's indoor air sampling in homes will be out in January or February 1998, and we want to publish again before then.

Please send in comments, questions, ideas for articles, letters, or whatever you want to be discussed in this newsletter. We won't think of everything, and we want your ideas and help. Send them to:

Steve Brittle
Don't Waste Arizona, Inc
6205 South 12th Street
Phoenix, AZ 85040,
or call the
CRSP 24-Hour Hotline
at 280-9908
and leave a message.

E-Mail Don't Waste Arizona, Inc.