E NVIRONMENTAL
     C OMPLIANCE
     O RGANIZATION

     Professional Waste Management Consultants
     106 Robinson Street Ashland, Virginia 23005      
     (804) 798-4305

     MEMORANDUM VIA FACSIMILE

     TO:       MIKE BAKER

     FROM:     PAULINE EWALD

     RE:       CONSTITUENTS OF CONCERN AT Bloomington SITES

     COPIES:   DAN CORTES, MELISSA VALENTIN, JOE HAILER

     DATE:     July 13, 1995

     I am in receipt of Dan Cortes' information regarding 
     chlorobenzenes and have re-reviewed some of the past sampling 
     data for Lemon Lane in that regard. Several chlorobenzenes are 
     included in the routine sampling parameters utilized in past 
     site work. However, the analytical parameters list is by no means 
     comprehensive. Recent research information suggests that there are 
     many potentially toxic contaminants that may be co-located with 
     PCBs, especially where as is the case with Lemon Lane, there has 
     been incomplete and uncontrolled burning. In the past, I have sent 
     along copies of some research articles documenting the existence of 
     these substances, but would be happy to duplicate the information 
     to any interested parties or provide copies for the bulletin board 
     upon request.

     These substances include dioxin and furan-like compounds where 
     bromide and sulfur substitute for the chlorine associated with 
     dioxin and furans. Although these compounds are not fully understood 
     to date, research data tends to suggest that these relatively 
     unknown chemicals, almost universally excluded from routine site 
     characterization and risk assessment have likely greater toxic 
     potential in regard to human health and the environment than the 
     dioxin and furans. Any truly comprehensive characterization of the 
     Bloomington sites must provide for the identification and 
     quantification of each of the organic chemicals listed below:

        co-planer PCBs

        polychlorinated dibenzothiophenes

        polychlorinated dibenzoxanthenes

        ploybrominated dibenzo-p-dioxins

        polybrominated dibenzo-furans

        bromo-chloro- dibenzo-p-dioxins

        bromo-chloro-dibenzo-furans

        brominated dibenzo-thiophenes

        brominated dibenzo-xanthenes

        chloro-bromo-dibenzo-thiophenes

        chloro-bromo-dibenzo-xanthenes

        co-plancr PBBs

        polychlorinated biphenylenes

        polybrominated biphenylenes

        chlorobenzenes

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