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Table 13. Concentrations Used to Estimate Exposure of Bystanders to Chloropicrin
from Structural Fumigation
Duration Sample Chloropicrin in Volume Measured Corrected
Interval Sample Sampled Concentration Concentration
Hours /sample) (m3 (gg/m a m3
I Hour 1.0 0.919 0.006 177 244
8 Hours d 8.0 1.29 0.0237 54.4 67.7
24 Hours e 23.0 1 3.90 10.114 34.2 49.7
Off -site concentrations measured during sulfuryl fluoride structural fumigation with chloropicrin as a
warning agent (Barnekow and Byrne, 2006).
a Time -weighted average concentration with 86.7% "study average" spike correction as reported by Barnekow
and Byrne (2006),
Concentrations above the limit of quantification corrected for 62.7% field spike recovery after reversing
correction applied by Barnekow and Byrne (2006).
d Highest rolling 8-hour concentration, calculated from consecutive 1- to 4-hour concentrations as follows:
[11.8 + 13.4 + 13.8 + 244 + (4 x 64.6)]/8 = 67.7 µg/m' (10.1 ppb).
e Highest rolling 24-hour concentration, calculated from consecutive 1- to 8-hour concentrations as follows:
7x41.2 + 8x39.1+ 11.8 + 13.4 + 13.8 + 244 + 4x64.6 /23=49.7 /m3 7.39 b
Water
Ground water contamination with chloropicrin could potentially be a pathway for airborne
exposure when well water is used, such as in households for showering. Chloropicrin is on
the list of pesticides that are considered to have the potential to contaminate' ground water
(Clayton, 2005). Chloropicrin is on this list based on its fairly high water solubility, its low
soil adsorption coefficient (K,,, = 25 cm3/g), and the relatively long half-life reported for
hydrolysis, which data suggest exceeds 191 days (Clayton, 2005).
Although chloropicrin has certain physicochemical properties that might predispose it to
leach into ground water, in extensive monitoring there have been no verified detections of
chloropicrin in California's ground water. DPR has not conducted any well monitoring for
chloropicrin in California; however, DPR has included in its groundwater monitoring
database results from sampling conducted by other agencies. The database, including criteria
for selection of wells and sampling and analytical methods, is described by Troiano et al.
(2001). Between 1984 and 1996, a total of 1,719 wells sampled in 34 California counties (out
of 58 counties total) were tested for the presence of chloropicrin (Schuette et al., 2003;
Nordmark, 2009), and chloropicrin was not detected in any of these samples. Detection limits
ranged from 0.01 to 5 µg/liter; most limits were at 1 µg/liter (Nordmark, 2009). No well
water sampling in California for chloropicrin has been reported since 1996.
ENVIRONMENTAL FATE
DPR released an Environmental Fate Review for chloropicrin in 1990 (Kollman, 1990). This
section briefly summarizes and updates information from that review. Following application
to soil, chloropicrin rapidly diffuses through the soil in all directions, then dissipates quickly,
with half-lives ranging from approximately an hour to several days. Volatilization is the
W,

major pathway through which chloropicrin dissipates from soil, but chloropicrin is also
degraded through biotic and abiotic reactions. In water, chloropicrin can persist for several
days in the absence of light, but it degrades rapidly when subjected to light of suitable
wavelengths, with half-lives ranging from 6 hours to 3 days. Under reducing conditions,
chloropicrin also reacts quickly, undergoing reductive dechlorinations. In air, chloropicrin is
reactive, undergoing photodegradation to products such as phosgene, ozone, nitrogen dioxide,
chlorine nitrate, and nitryl chloride, with an estimated half-life in the range of 3 — 18 hours
under constant illumination in the laboratory.
Persistence in Soil Environment
As a soil fumigant, chloropicrin is applied to soil via either injection with shank or similar
equipment, or via drip irrigation. After application to soil, chloropicrin rapidly diffuses
through the soil in all directions, although it moves less rapidly than the more volatile methyl
bromide (Wilhelm, 1960; Youngson et al., 1962; Gan et al., 2000; Desager et al., 2004).
Volatilization from soil is the major off -site loss pathway, followed by chemical degradation
and microbial decomposition (Gou et al., 2003). Chloropicrin disappearance from treated
soils is well -described by first -order kinetics (Gan et al., 2000; Ibekwe et al., 2004; Zhang et
al., 2005).
Volatilization from Soil
Both the vapor pressure and Henry's Law Constant for chloropicrin are relatively high, 23.2
mm Hg and 2.5 x 10-3 atm-m3/mole, respectively, at 25°C (See Table 1). Field volatility data
suggest that substantial proportions of applied chloropicrin are emitted from soil. Field
volatility studies reported by Beard et al. (1996) and Rotondaro (2005) were summarized
above in the Environmental Concentrations section. As listed in Table 10, in these studies it
was determined that over 2-week intervals, on average 61 — 69% of the chloropicrin applied
by shank fumigation volatilized, while 15% of chloropicrin applied by tarped drip fumigation
volatilized over 2 weeks.
Abiotic and Microbial Reactions with Chloropicrin in Soil
Chloropicrin is rapidly degraded in soil under both aerobic and anaerobic conditions (Olson
and Lawrence, 1990a and 1990b; Wilhelm et al., 1996; Gan et al., 2000). Field dissipation
studies reported degradation half-lives between 1 and 8 days, depending on the formulation,
application method and soil type (lvancovich et al., 1990). Studies of soil repeatedly treated
with chloropicrin suggest that enrichment can occur of the microorganisms capable of
degrading chloropicrin (Ibekwe et al., 2004; Zhang et al., 2005).
Laboratory soil metabolism studies also report chloropicrin degradation half-lives in the range
of a few hours to several days. The estimated half-life when 250 ppm of 14C-radiolabeled
chloropicrin was incubated with sandy loam under aerobic conditions was approximately 5
days; about 70% of the applied radiolabel was recovered by the 901h day of the study as COz,
while most of the rest was volatilized chloropicrin (Olson and Lawrence, 1990a). In an
anaerobic soil metabolism study, Olson and Lawrence (1990b) incubated 250 ppm
chloropicrin with sandy loam under aerobic conditions for 5 days post -application (i.e., the
M,

aerobic half-life); the soil was then made anaerobic by flushing with nitrogen gas 5 days post -
application. Although a half-life was not calculated for chloropicrin under anaerobic
conditions because the only sampling intervals were 30 and 60 days after the soil was made
anaerobic, Olson and Lawrence (1990b) reported that dissipation was "rapid." The anaerobic
half-life was assumed to be shorter than 10 days, as no parent chloropicrin was recovered 35
days post -application (Lawrence, 1990). As with the aerobic soil metabolism study, the
radiolabel was predominantly recovered in CO2 and the parent compound, with CO2
averaging up to 16.4% of the total applied. However, total recovery of the radiolabel was
poor, ranging from an average of 50.2% immediately following treatment to an overall mean
total recovery of 74.3% on the 301h and 60`h days post -application. Olson and Lawrence
(1990b) concluded that losses occurred during the sampling procedure.
In a laboratory study, chloropicrin degraded rapidly when incubated in 100-g samples of
Wooster sandy loam collected from Ohio (Craine, 1985b). Aliquots of a chloropicrin solution
consisting of 11.35 mg in I ml ethanol were pipetted into flasks containing 100 g of soil.
Flasks were incubated in the dark at 25°C under aerobic conditions and sampled hourly for 24
hours; concentrations of chloropicrin and inorganic chloride were determined in the samples.
Within the first hour, the chloropicrin was reduced to 48.7% of the initial dose, yielding an
estimated half-life of about 1 hour. After 24 hours, approximately 91 % of the chloropicrin
had degraded. Conversion of chloropicrin to inorganic chloride had an estimated half-life of
9.9 hours. Craine (1985b) also investigated anaerobic metabolism of chloropicrin; water was
added to the flasks to induce anaerobic conditions. The mean chloropicrin degradation half-
life was reported to be 17 hours in the soil -water slurries.
Wilhelm el al. (1996) reported on an aerobic soil metabolism study in which 50-g sandy loam
soil samples were treated with 14C-chloropicrin at a rate equivalent to 500 lbs AI/acre (562 kg
Al/ha), then incubated in the dark at 25°C. Samples were collected after 4.5 hours, and at 1,
2, 3, 6, 14, 21, and 24 days post -dose. Overall recovery was 97.2% of the applied radiolabel.
The estimated half-life for chloropicrin was 4.5 ' days. After 24 days, up to 75.2% of the
applied radiolabel was recovered as "C-0O2.
Gan el al. (2000) investigated the aerobic metabolism of chloropicrin in 10-g samples of three
soils, including Arlington sandy loam from California, Carsitas loamy sand from California,
and Waukegen silt loam from Minnesota, with respective organic matter content of 0.92%,
0.22%, and 3.1%. In all three soils (with initial water content adjusted to 10%), chloropicrin
degradation increased 7- to I 1-fold as soil temperatures increased in the range 20°C — 50°C.
In contrast, variation of soil moisture content,'which was tested only in Arlington and Carsitas
soils, had little effect. With soil temperatures held at 20°C, and soil moisture ranging 1.8% —
l6%, degradation in chloropicrin doubled from the high to low moisture contents in Arlington
sandy loam, but did not change across the same moisture range in Carsitas loamy sand. In a
laboratory study with loamy sand from a Wisconsin nursery, Zhang et al. (2005) found no
change in chloropicrin degradation rates when moisture ranged 0.5% — 10%, but the
degradation was significantly lower at a moisture content of 15%.
47

Gan et al. (2000) found that degradation was slower in sterile soil: in untreated, air-dried soil,
the half-life was 1.5, 4.3, and 0.2 days for the Arlington, Carsitas and Waukegen soils
respectively, while in autoclaved soils the respective half-lives were 6.3, 13.9, and 2.7 days.
Based on the difference in the degradation between the sterile and non -sterile soils, Gan et al.
(2000) estimated that microbial degradation accounted for 68 — 92% of the chloropicrin
degradation. In similar studies, Zheng et aL (2003) estimated that microbial degradation of
chloropicrin in a sandy loam from California accounted for 84% of the total chloropicrin
degradation, and Zhang et al. (2005) estimated the microbial contribution to chloropicrin
degradation in loamy sands from Wisconsin and Georgia to range between 40%and 80%.
Chloropicrin is degraded in soil by Pseurlomonas bacteria via a metabolic pathway involving
dehalogenated intermediates dichloronitromethane, chloronitromethane, and nitromethane,
apparently formed in sequence (Castro et al., 1983):
CC13NO2 => CHC12NO2 => CH2CINO2 =:> CH3NO2
Alternately, Cervini-Silva (2000) found evidence that formation of dichloronitromethane and
chloronitromethane can occur simultaneously via abiotic oxidation-reduction reactions in the
presence of strong electron donors such as those found in iron -bearing soils.
Other reaction products of chloropicrin in soil have been documented as well. Spokas and
Wang (2003) noted increased emissions of nitrous oxide (N2O) following soil fumigation with
chloropicrin, in both laboratory and field studies; in the field, daily N2O emissions increased
7-fold during the first 10 days post -fumigation before decreasing to background levels.
Follow-up laboratory studies using radiolabels and microbial inhibitors caused Spokas et al.
(2006) to conclude that in the Georgia loamy sand treated in their studies, about 20% of the
increased N2O production could I be attributed to microbes sensitive to tetracycline and
streptomycin, while 70% — 80% was due to fungi sensitive to cycloheximide and benomyl.
Following studies in which chloropicrin was incubated with steam -sterilized soil, Spokas et
al. (2006) concluded ,that at most 18% of the increase in N2O was from abiotic reactions,
although they could not verify that sterilized soil did not have residual biotic activity. 15N-
labeled chloropicrin yielded a significant increase of 15N-N20, yet only about 12% of the 15N-
N20 was calculated to come from chloropicrin mineralization; most of the 15N came from
other pools in the treated soil (Spokas et al., 2006). Increasing the oxygen content in the
headspace of the incubation vials to 30% further increased N2O, to about 5-fold greater than
amounts occurring when chloropicrin was incubated at ambient oxygen concentrations.
Although chloropicrin increases production of N2O, no increased production of nitrogen, CO2
or methane occurred in soils incubated with chloropicrin in comparison to soils incubated
without chloropicrin (Spokas et aL, 2005; Spokas et aL, 2006).
Adsorption to Soil
The soil/water adsorption coefficient (Kd; ratio of chemical concentrations in soil and water)
of chloropicrin was investigated in a series of laboratory experiments with 50-g samples of
four soil types, including commercially purchased agricultural sand, Canfield sandy loam,
48

Wooster sandy loam, and Holly sandy loam (Craine, 1985c). Other than the purchased sand,
soils were collected from several locations near Ashland, OH, and sifted through 0.25-inch
(0.64-cm) mesh. The sandy loams were misidentified by Craine (1985c) as silt loams, but the
correct soil texture can be determined using a nomogram in USDA (2007). The organic
matter content of the soils was 0.3% for the agricultural sand, 5.5% for the Canfield sandy
loam, 7.2% for the Wooster sandy loam, and 7.4% for the Holly sandy loam. Chloropicrin in
an ethanol solution was added in amounts ranging from 9 to 127 mg/kg soil. A soil -free
control bottle containing the same amount of chloropicrin as the soil samples was used to
determine loss of chloropicrin during the sampling procedure, which ranged 26% — 50% of
the amount applied, and the amount of chloropicrin that degraded in soil samples, which
ranged 10%= 61%. After the I -hour incubation period, 200 ml water was added to flasks,
and the amount of chloropicrin in water and soil was determined. The estimated chloropicrin
adsorbed to soil ranged from 2.8% — 16.2%. The mean Kd ranged from 0.179 to 0.311 for the
sandy loam soils and was 0.273 for the agricultural sand; the mean soil absorption coefficient
(K�; soil adsorption normalized to soil organic matter content) was 25 cm3/g (calculated by
DPR's Environmental Monitoring Branch, internal database). In a subsequent
communication, Craine (1986) noted that because of the "rapid rate at which chloropicrin is
metabolized in soil," no equilibrium between adsorption and desorption could be established
in the 1-hour interval monitored in this study.
Kenaga (1980) calculated a Ko, of 62 for chloropicrin, based on a reported water solubility of
2,270 ppm. The calculation used a regression of K, on water solubility for 170 chemicals.
The regression equation was K0, = 3.64 — 0.55(log water solubility).
Although chloropicrin rapidly dissipates from soil under many conditions, in some cases
residual amounts can persist. For example, Guo et al. (2003b) report a case in which soil
beneath a facility in Maine that had formerly manufactured several chemicals, including
chloropicrin, contained residues as high as 500 mg/kg 7 years after manufacturing ceased and
the facility was abandoned. Chloropicrin concentrations in ground water beneath the -facility
ranged 10 — 150 mg/l (Guo et al., 2003b).
To investigate chloropicrin's persistence in soil, Guo et al. (2003a) conducted a laboratory
study with triplicate 10-g samples of sandy loam, loam, and silt loam soils from California
and Pennsylvania. Samples were mixed with chloropicrin at an initial concentration of 1,690
mg/kg (i.e., 10 µl chloropicrin in 10 g soil) and incubated in the dark at 20°C for 30 days.
Following incubation, soils were thinly spread onto foil sheets in a fume hood, and residues
were allowed to evaporate for 20 hours, after which the remaining residues were extracted.
The average residues extracted from the incubated soil ranged from 0.7% in the sandy loam to
4.0% in the silt loam. Extending the evaporation from 20 hours to 120 hours had little effect
on the persistent residues, nor did shortening the incubation time to 10 days. Soils incubated
for less than 10 days had lower persistent residue levels.
49

Leaching from Soil
Laboratory data,suggest that under some conditions chloropicrin residues could leach into
ground water. Guo et al. (2003b) investigated the leaching potential of persistent chloropicrin
residues in silt loam from Pennsylvania. Triplicate samples of soil were mixed with
chloropicrin at an initial concentration of 845 mg/kg (i.e., 150 µl chloropicrin in 330 g soil) at
20°C for 35 days. Following incubation, soils were thinly spread onto foil sheets in a fume
hood, and residues were allowed to evaporate for 48 hours. Aliquots of this treated soil were
mixed with deionized water (10 g soil, 8 ml water). After an additional 24 hours, the
mixtures were centrifuged (at 956 x gravity for 15 minutes), and an average of 2.10 mg/l
chloropicrin was quantitated in the supernatant. Follow-up soil column studies by Guo et al.
(2003b) suggested that under conditions of high water movement through soil and limited
microbial activity, substantial amounts of chloropicrin could potentially leach into ground
water.
Persistence in Water Environment
Chloropicrin persists in water for several days in the absence of light, but degrades rapidly
when subjected to light of suitable wavelengths, with half-lives ranging from 6 hours to 3
days (Castro and Belser, 1981; Chang, 1989; Moreno and Lee, 1993). Under reducing
conditions, chloropicrin undergoes a series of reductive dechlorinations (Zheng el al., 2006;
Lee et al., 2008). In addition to leaching from pesticide applications, chloropicrin is also
formed in water with high organic content as a byproduct of certain disinfection chemicals,
although environmental concentrations are invariably low. The potential for chloropicrin to
bioconcentrate in aquatic organisms is also anticipated to be low.
Hydrolysis
Craine (1985a) investigated chloropicrin hydrolysis in 250-ml aliquots of aqueous solutions
at pH 5, 7 or 9. The solutions, with initial chloropicrin concentrations of 110 mg/I, 42.1 mg/l,
and 205 mg/l, respectively, were incubated in sealed 550-ml Erlenmeyer flasks in the dark at
either 25°C or 35°C for 29 days. Preliminary experiments without water showed that flasks
would retain chloropicrin for 29 days, although "inconsistent" chloropicrin losses occurred
during headspace sampling. Samples of headspace gases and of solution were collected at 0,
2, 4, 9, 14, 21, and 29 days. Chloroform was detected in trace amounts in several flasks, at all
three pH levels. No other organic degradation products were detected by gas chromatography
with either 63Ni or flame ionization detectors; reference standards of chloropicrin, chloroform,
methane, methanol, and nitromethane were used to calibrate the detectors. Inorganic chloride
in the solutions was quantitated with an ion -specific electrode, and was corrected for amounts
initially present in the buffered solutions. Recognizing that each chloropicrin molecule
contains three chlorine atoms, the theoretical maximum inorganic chloride concentration in
each solution could be calculated from the initial chloropicrin concentration. The highest
measured amount of inorganic chloride in each solution ranged from 0.8% of the theoretical
maximum at pH 5 and 25°C to 63.3% of the theoretical maximum at pH 7 and 35°C. Craine
(1985a) calculated rates of hydrolysis at each pH and temperature; in general, rates increased
with temperature and pH, with the slowest rate at pH 5 and 25°C (0.8 µmol/liter/day) and the
highest at pH 9 and 35°C (165.2 µmol/liter/day).
50

In contrast to Craine (1985a), Chang (1989) found limited hydrolysis of chloropicrin in 100-
mg/l aqueous solutions at pH 5, 7 and 9. To prevent volatilization, all vials were filled to the
top, without any hcadspace, and capped tightly. The foil -wrapped vials were incubated in that
dark at 25°C. Three vials were sampled at 0, 2, 4, 9, 14, 21, and 28 days. Inorganic chloride
in the solutions was quantitated with an ion -specific electrode, and chloropicrin was
quantitated by gas chromatography with a flame ionization detector. In all solutions, final
chloropicrin concentrations were at least 90% of initial, and inorganic chloride never
exceeded the detection limit of 1.5 mg/l.
Jeffers and Wolfe (1996) investigated chloropicrin hydrolysis at elevated temperatures (85 —
166°C) in aqueous 0.0003 µmol/1 solutions sealed in Pyrex glass bulbs. Detectable hydrolysis
occurred only at temperatures greater than 140°C, and Jeffers and Wolfe (1996) concluded
that "homogeneous hydrolysis is a completely negligible process for chloropicrin." However,
in another set of experiments, chloropicrin in an aqueous 0.0006 µmoll) solution was
incubated with 0.5 g of an aquatic plant, parrot feather, and degraded via reduction to
dichloronitromethane then chloride ion, with a half-life that was less than 20 hours. Jeffers
and Wolfe (1996) concluded, based on this experiment and others with halogenated
compounds, that "plant dehalogenases will degrade chloropicrin readily and completely,
within 20 hours, as `reasonable' concentrations."
Another study also reported a lack of hydrolysis in chloropicrin solutions incubated in the
dark for r 10 days (Moreno and Lee, 1993). This study is described below, in the
Photohydrolysis section.
Photohydrolysis
Castro and Belser (1981) investigated hydrolysis of an aqueous, 0.01-M (1,640 mg/1)
chloropicrin solution in a tube -shaped quartz photoreactor irradiated with a small, low-
pressure quartz lamp at 254 nm. The photoreactor contained 100 ml solution and 115 ml
headspace. Inorganic chloride was quantitated with an ion -specific electrode, chloropicrin
was quantitated by gas chromatography with a flame ionization detector, nitrate was
quantitated spectrophotometrically as nitrotoluene following reaction with toluene, and
carbon dioxide was quantitated by gravimetric determination of barium carbonate after
reaction with barium hydroxide. Following a 24-hour incubation at 25°C, no detectable
chloropicrin remained in solution or in the headspace. Inorganic chloride was present at
0.003 M, nitrate at 0.00105 M, and carbon dioxide (in gas and solution) at 0.00097 M.
Kinetics experiments with this apparatus showed that chloropicrin dissipated completely after
6 hours in light at 254 rim.
Additional kinetics experiments conducted by Castro and Belser (1981) investigated
chloropicrin hydrolysis in solution under ambient light conditions, under a 150-watt flood
lamp, and exposed to sunlight in a quartz cuvette in August. The latter two conditions yielded
identical decay curves, with a half life of 3 days. Under ambient light, however, negligible
hydrolysis occurred after 10 days. Castro and Belser (1981) concluded that photohydrolysis
51

was proportional to the light available in the blue and ultraviolet regions of the
electromagnetic spectrum. Furthermore, Castro and Belser (1981) concluded the fact that
inorganic chloride was not formed at the expected rate of three times the disappearance of
chloropicrin indicated the presence of chlorinated intermediates, which their analyses were
not able to identify.
The hydrolysis of chloropicrin in a pH 7 aqueous 0.001-M solution was investigated by
Moreno and Lee (1993); this study was also described by Wilhelm et al. (1996). Aliquots of
the solution were injected with a syringe into 12-ml Teflon -sealed vials, leaving no
headspace, and incubated at 25°C under both dark and simulated -sunlight conditions (Suntest
CPS photomachine with xenon lamp, 12-hour light/dark cycles). Three to five vials were
sampled at 12, 24, 36, 48, 60, 72, 84 and 108 hours. Chloropicrin was quantitated by gas
chromatography with a flame ionization detector, carbon dioxide was quantitated by gas
chromatography/mass spectrometry, and a combination pH/ion analyzer was used to measure
pH and to quantitate nitrate, nitrite, and chloride concentrations. There was no measurable
hydrolysis of chloropicrin after 10 days under dark conditions. However, chloropicrin
underwent significant photodegradation with simulated sunlight. The estimated half-life was
31.1 hours. After 10 days, the chloropicrin concentration had declined to 91% of its initial
concentration. The degradation products identified included carbon dioxide (a portion of
which would ionize in solution to bicarbonate at the pH tested), chloride, nitrate and nitrite.
Oxidation -Reduction Reactions
Under reducing conditions, chloropicrin undergoes a series of dechlorinations (Zheng et al.,
2006; Lee et al., 2008). To investigate reactions with reduced sulfur compounds, 50-m1
aliquots of a deoxygenated 0.0005-M chloropicrin stock solution were mixed with a
deoxygenated sulfide solution in 55-ml serum bottles capped with Teflon -faced butyl rubber
stoppers, and incubated in the dark at 25°C (Zheng et al., 2006). Hydrolysis controls
contained only chloropicrin solution. Chloropicrin was quantitated by gas chromatography
with an electron capture detector, and transformation products were analyzed by gas
chromatography/mass spectrometry. Chloropicrin reacted completely with 'the sulfide
solution, and was non -detectable in less than 1 hour; decay was exponential. The reaction
was increased more than 20-fold when pH was increased from 5.8 to 8.9. In contrast, no
discernable hydrolysis occurred in the chloropicrin-only controls. Transformation products
from the chloropicrin-sulfide reactions included dichloronitromethane and
chloronitromethane. These products formed simultaneously in kinetics experiments,
suggesting that the reactions involve formation of radicals. Zheng et al. (2006) suggest that
such reactions may be a significant pathway for chloropicrin dissipation in the environment,
especially after drip irrigation applications where the saturated soil becomes anoxic.
Laboratory experiments by Lee et al. (2008) suggest that reduced iron species, like the
reduced sulfur species used by Zheng et al. (2006), quickly and quantitatively react with
chloropicrin to form dichloronitromethane and nitromethane. In their study, Lee et al. (2008)
determined the half-life of such reactions to be less than 5 minutes.
52

Chloropicrin as a Disinfection Byproduct in Drinking Water
In addition to its presence in water following pesticide applications, chloropicrin
concentrations occur as a byproduct of reactions between organic matter and certain water
treatment chemicals used in chlorination, as well as other oxidative treatments used to
disinfect drinking water (Merlet et al., 1985). Chloropicrin is a minor disinfectant byproduct,
as it is formed at a rate that is at least 10-fold slower than major byproducts such as
chloroform and is present in low concentrations (< 10 µg/L) under all conditions that have
been investigated (Hoignd and Bader, 1988; Lee et al., 2007; Yang el al., 2007).
Chen and Weisel (1998) monitored several disinfection byproducts at three locations in a
drinking water distribution system in New Jersey, in which free chlorine levels were
maintained at 0.5 mg/L to prevent regrowth of microorganisms. Chloropicrin concentrations
ranged from below the LOD of 0.05 µg/L to 0.9 µg/L. Mean chloropicrin concentrations
were 0.1 µg/L in winter and 0.5 µg/L in summer. However, chloropicrin concentrations
decreased with residence time in the distribution system, suggesting that chloropicrin was
formed during treatment then dissipated following treatment; in contrast, most other
byproducts continued to be formed during distribution of drinking water from the treatment
plant (Chen and Weisel, 1998). Wells et al. (2001) found that grab samples of Seattle tap
water contained chloropicrin at a mean concentration of 0.249 µg/L (n = 3), but that boiling
tap water samples for 5 minutes decreased chloropicrin concentrations to below the LOD of
0.009 µg/L.
Krasner el al. (1989) collected quarterly water samples, from spring 1988 through winter
1989, at 35 utilities across the U.S. (ten of which were in California). These samples were
analyzed for a number of disinfection byproducts, including chloropicrin. Results were
reported as quarterly means across all 35 utilities; the quarterly mean for chloropicrin ranged
0.10 µg/L to 0.16 µg/L. Krasner el al. (1989) selected utilities operating under a wide variety
of conditions. In a later study, Krasner et al. (2006) selected ten utilities with water sources
high in organic carbon or bromide. Results were aggregated across all ten plants; the
maximum chloropicrin concentration reported was 2.0 µg/L, and the median concentration
was 0.2 µg/L.
Bioconcentration in Aquatic Organisms
Bioconcentration/bioaccumulation is defined by U.S. EPA (1996) as "the increase in
concentration of the test substance in or on an organism (specified tissues thereof) relative to
the concentration of test substance in the surrounding medium." Bioconcentration refers
specifically to uptake of a substance solely from water. The bioconcentration factor (BCF) is
the ratio of concentrations in fish tissues (expressed as wet weight of the fish) and
surrounding water. A high BCF suggests a potential for a compound to segregate into body
lipids rather than be excreted, and might be predicted from a high K,,,,, (Franke, 1996).
The relatively low Ko,N and high water solubility of chloropicrin suggest that bioconcentration
in aquatic organisms is likely to be low. Kenaga (1980) calculated a BCF of 8, based on a
reported water solubility of 2,270 ppm. The calculation used a regression of BCF on water
53

solubility for 170 chemicals. The regression equation was log BCF = 2.791 — 0.564(log water
solubility). -
Using the Estimation Program Interface, a software package available from U.S. EPA that
relies on K,,, to predict the BCF, Sanderson et al. (2007) predicted a BCF of 8.1 for
chloropicrin.
Persistence in Air Environment
Chloropicrin is reactive and has a relatively short half-life in sunlight. The: importance of
photolysis as a primary mechanism for degradation of chloropicrin vapor is emphasized by a
laboratory study conducted by Moilanen et al. (1978), in which negligible chloropicrin loss
occurred over 70 days at 25°C — 30°C. Under laboratory conditions with simulated sunlight,
chloropicrin vapor undergoes photodegradation, with initial cleavage of the C-N bond to form
trichloromethyl radical and an electronically excited species of nitrogen dioxide; subsequent
reactions form products such as phosgene, ozone, chlorine nitrate, and nitryl chloride. The
estimated photolysis half-life is in the range of 3 — 18 hours under constant illumination
(Allston el al., 1978; Carter et al., 1997; Hatakeyama et al., 1999; Wade et al., 2007). Carter
et al. (1997), citing reviews of atmospheric reactions of halogenated and nitro compounds by
Atkinson (1989 and 1994), stated that the only significant reactions of chloropicrin in air are
due to photolysis rather than reaction with radical species such as OH, ozone, and NO3.
Photolysis
The photodegradation of chloropicrin in the vapor phase was analyzed by Moilanen et al.
(1978) in the laboratory under simulated sunlight (275-W RS Sunlamp). Chloropicrin was
vaporized in a photoreactor at 0.1, 1.4 and 14 g/ml and irradiated at sunlight wavelengths (>
290 nm) continuously for 70 days at 25°C — 30°C. Control flasks incubated at the same
temperature but in the dark showed little chloropicrin loss over the 70-day study. The
photodegradation half-life was 20 days for all three concentrations tested. The initial
photodegradation products were phosgene (COC12) and nitrosyl chloride (NOCI) resulting
from the photochemical oxygenation of chloropicrin, with the following overall equation:
CC13NO2 => COC12 + NOCI
Moilanen et al. (1978) concluded that this reaction required the presence of oxygen
(Moilanen et al., 1978), for two reasons. First, chloropicrin was stable when irradiated in a
nitrogen atmosphere or in a flask from which oxygen was excluded. Second, when irradiated
in the presence of 1802, a labeled oxygen atom appeared on newly -formed phosgene.
Moilanen et al. (1978) proposed a mechanism with trioxazole intermediates to account for
these results. Following its formation as an initial product of chloropicrin photolysis, nitrosyl
chloride underwent photodegradation to nitric oxide (NO) and chlorine (CIA the former
oxidized further to yield nitrogen dioxide (NO2). The accumulation of phosgene during the
experiment indicated that it was relatively stable in the flasks under these experimental
conditions, but Moilanen et al. (1978) predicted that in the atmosphere it would "be subject to
rapid dissipation," hydrolyzing to yield carbon dioxide and hydrogen chloride. Helas and
54

r
Wilson (1992) estimated phosgene's lifetime to be a few days at ground level, based on
laboratory data.
Carter et al. (1997) measured chloropicrin absorption across the spectrum ranging 190 — 800
nm, and identified two maxima in the ranges 216 — 220 nm and 274 — 276 nm. Although
Carter et al. (1997) observed no significant absorption at wavelengths above 370 nm,
sufficient absorption occurred in the range 300 — 360 nm to suggest that photolysis will occur
in ambient sunlight. Chloropicrin photodegradation was measured in two environmental
chambers consisting of 4' x 4'x 8' interconnected Teflon reaction bags. The chambers were
mounted side -by -side in a room with reflective walls, and irradiated with four xenon arc
lamps at the opposite end of the room. The half-life was estimated at 18 hours, and with
assumptions that 0.87 + 0.26 moles of chloropicrin will photodegrade per mole of photons
absorbed and that their chamber conditions closely approximate daytime conditions (except
with higher light intensity from sunlight), Carteret al. (1997) predicted that in ambient
sunlight the half-life would range 3.4 — 7.6 hours. These values are considerably less than the
20-day half-life reported by Moilenen et al. (1978), probably due to differences in light
intensity at the locations of the spectrum where chloropicrin absorption occurs (Carteret al.,
1997). Furthermore, Carter el al. (1997)' found that photolysis occurred in a nitrogen
atmosphere; they suggested that the fact the photolysis did not need oxygen in their
experiments, along with the much faster reaction rate in their experiments than reported by
Moilenen el al. (1978), might indicate that different wavelengths favored different
mechanisms, with the trioxazole mechanism dominating only at wavelengths longer than 360
nm. Carter el al. (1997) concluded that at wavelengths in the range of 300 — 360 nm, their
data were more consistent with initial cleavage of the C-N bond with formation of a
trichloromethyl radical KC13) and an electronically excited species of nitrogen dioxide
(NO2) as the major mechanism:
CC13NO2 => -CC13 + NO2;
Chloropicrin reactivity with several organic compounds was also monitored in the
photoreactors by Carter et al. (1997). Chloropicrin reacted with the organic compounds, and
catalyzed formation of ozone, but at a much slower rate than chlorine.
Hatakeyama et al. (1999) monitored photodissociation of chloropicrin in air at 1 atm in a 6-
m3 reaction chamber irradiated with nineteen 1-kW xenon arc lamps having a light intensity
of 0.2/min. Concentrations of chloropicrin and its reaction products were monitored with
Fourier transform infrared emission spectroscopy; a total of 64 repeat scans were run at I
cm/min resolution (neither reaction time nor scan time were reported). Hatakeyama et al.
(1999) estimated a first -order photodecomposition rate of 9.6 x 10-4/min, which corresponds
to a half-life of 12 hours. They identified the following photoproducts in the chamber:
phosgene, ozone, nitrogen dioxide, chlorine nitrate, and nitryl chloride. Nitrosyl chloride was
not observed; Hatakeyama el al. (1999) suggested that it would photolyze too rapidly to be
detected in their system. Phosgene was formed at almost a 1:1 ratio with the amount of
chloropicrin added, which ranged from 500 — 2,000 ppb. Hatakeyama et al. (1999) agreed
with Carter el al. (1997) with regard to the primary mechanism of chloropicrin photolysis.
55

Wade et al. (2006) conducted detailed studies of chloropicrin photodissociation at room
temperature using a series of unfocused lasers to specifically excite chloropicrin at
wavelengths of 193 nm (argon fluoride laser), 248 nm (krypton fluoride laser), and 266 nm
(neodimium:yttrium aluminum garnet laser). Emission spectra were monitored for I — 2%
chloropicrin vapor in helium buffer gas using step -scan Fourier transform infrared emission
spectroscopy. Wade et al. (2006) concluded that the primary response of chloropicrin to light
at these wavelengths was to form •CC13 and NO2*, the mechanism supported by Carter et al.
(1997) and Hatakeyama et al. (1999). Both compounds rapidly react to form other products,
such as nitric oxide. The evidence suggested that phosgene and nitrosyl chloride are
secondary products of subsequent reactions (Wade et al., 2006).
Preliminary reports from two additional studies, with limited descriptions of experimental
conditions, suggest photolysis lifetimes of 3 — 5 hours for chloropicrin (Allston et al., 1978;
Vera et al., 2007). Allston et al. (1978) analyzed a total of 19 absorption spectra of
chloropicrin run over the wavelength range 190 — 400 nm. In that range, chloropicrin
absorbed light between 190 nm and 375 rim, with absorption maxima at 202 + I nm and 272
+ 2 nm. Assuming photolysis of 1 mole of chloropicrin per mole of photons absorbed,
Allston el al. (1978) calculated a photodissociation lifetime at ground level of 4.8 hours.
Vera et al. (2007) briefly described a photolysis study conducted in a simulation chamber in
an outdoor photoreactor named "EUPHORE," located in Spain. The two dome -shaped
EUPHORE chambers each have a volume of 200 m3, and are covered by a Teflon foil that is
approximately 85% transparent to sunlight. Photolysis of 300 ppb chloropicrin in sunlight
was monitored in one of the chambers, and Vera et al. (2007) reported a photolysis lifetime of
approximately 3 hours, with production of phosgene, NO and NO2.
EXPOSURE ASSESSMENT
Exposure estimates are provided for short-term (defined in this exposure assessment as acute
and up to one week) and, where appropriate, for seasonal (intermediate -term intervals, lasting
from one week to one year), annual, and lifetime exposures. Short-term exposures were
estimated for 1-hour durations because chloropicrin irritation occurs rapidly, and I hour is the
shortest duration for which toxicity endpoints and concentrations can reasonably be
estimated. Short-term estimates of 8-hour and 24-hour durations are included to address
occupational and residential exposures.
For short-term exposures, DPR estimates the highest exposure an individual may realistically
experience during or following legal chloropicrin uses. To estimate seasonal, annual, and
lifetime exposures, the average daily exposure is of interest because over these periods of
time, an individual is expected to encounter a range of daily exposures (i.e., DPR assumes
that with increased exposure duration, repeated daily exposure at the upper -bound level is
unlikely). Typical exposure conditions are assumed for seasonal and annual exposure
estimates. An annual exposure is a time -weighted average concentration that integrates use of
chloropicrin throughout the year, and a lifetime exposure estimate averages daily exposure
over a lifetime.
56

Jones, Jennifer
From:
Schimizzi, Nikki
Sent:
Tuesday, November 29, 2011 3:30 PM
To:
Jones, Jennifer
Cc:
Brower, Connie
Subject:
FW: EPA test method 9020 - total organic halides
Hi Jen,
See Anne's response from the chemistry lab below regarding your question on test methods. I don't think that you were
copied (sorry for the duplicate if you already have this). I'm not sure if her email will help you or not. You can give her a
call directly if you want to have further clarification on the test methods. Connie and I don't have anything to add on
this question as it is out of our knowledge range (these are apparently not often used tests as it appears from Anne's
response that the chem lab doesn't have any experience with them either). Sorry that we couldn't be of more help.
Nikki
Please note new e-mail address: [e-mail]
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Chandler, Anne
Sent: Tuesday, November 22, 2011 3:35 PM
To: Schimizzi, Nikki
Subject:.FW: EPA test method 9020 - total organic halides
Nikki,
Below is my reply to Connie. I meant to "reply to all".
Organic Chemistry Branch Manager
[e-mail]
NC DWQ Laboratory section Website: NCDENR - DWQ Lab
1623 Mail Service Center Phone: [phone] x224
Raleigh, NC 27699-1623 Fax: [phone]

Email correspondence to and from this address is subject to the North Carolina Public Records kaw aM
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Chandler, Anne
Sent: Tuesday, November 22, 2011 3:33 PM
To: Brower, Connie
Subject: RE: EPA test method 9020 - total organic halides
Hi Connie,
We've never seen chloropicrin that we can remember. Yes, 551 is a drinking water method 1 believe. Below is from the first of
Method 9620, which of course we have no experience with.
1,1 Method 9020 determines Total Organic Halides (TOX) as chloride in
drinking water and ground waters. The method uses carbon adsorption with a
microcoulometric-titration detector. -
1.2 Method 9020 detects all organic halides containing chlorine,
bromine, and iodine that are adsorbed by granular activated carbon under the
conditions of the method. Fluorine -containing species are not determined by this
gate Z. &4mi in
Organic Chemistry Branch Manager
I
Anne.Chandler0ancdenr.gov
NC DWQ Laboratory Section Website: NCDENR - DWQ Lab
1623 Mail Service Center Phone: [phone] x224
Raleigh, NC 27699-1623 Fax: [phone]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Brower, Connie
Sent: Tuesday, November 22, 2011 1:59 PM
To: Schimizzi, Nikki; Chandler, Anne
Subject: RE: EPA test method 9020 - total organic halides
Have you ever seen chloropicrin in the waters? And isn't 551 a drinking water method? I've been away too long...
Ahhhl! can I come back and bring my dear friend Nikki with me?
-c-
From: Schimizzi, Nikki
Sent: Tuesday, November 22, 2011 11:36 AM
To: Chandler, Anne
Cc: Brower, Connie; Jones, Jennifer
Subject: FW: EPA test method 9020 - total organic halides
Hi Anne,
Would you have any thoughts on the below question sent to us by Jennifer Jones in DWQ's stormwater permitting unit?
Connie and I didn't have a good response to this and thought it best to ask the experts!

a
0
Thank you!
Nikki
Please note new e-mail address: [e-mail]
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Jones, Jennifer
Sent: Tuesday, November 22, 2011 11:27 AM
To: Schimizzi, Nikki; Brower, Connie
Cc: Lawyer, Mike; Jones, Jennifer
Subject: EPA test method 9020 - total organic halides
Hi Nikki and Connie,
I am writing a permit for a facility that manufactures chloropicrin - http://en.wikipedia.org/wiki/Chloropicrin. It is a soil
fumigant used as a nematocide and fungicide. It also used to be used in chemical warfare. They also make bleach as a
by-product.
The facility told us that "there wasn't a test for chloropicrin" so I called two labs — Tritest and Prism.
• Tritest said they could test for it using EPA test method 551, but it might be a bit difficult, and they don't
routinely do it. That is a GC test.
• Prism said that the nitro group can mess up the GC, and he'd recommend using EPA test 9020 — total organic
halides. This is a screen for the entire category of organic halides — of which chloropicrin is one of.
I was not planning on adding a benchmark for chloropicrin or halides —just testing to see presence/absence. Would you
have a recommendation for one of these tests over the other (and why)?
Thanks ladies!
Jen
Jennifer Jones
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.org/web/wg/wslsu

** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
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Extension Toxicology Network
A Pesticide Information Project of Cooperative Extension Offices ofCome11 University, Michigan State University, Oregon
State University, and University of California at Davis. Major support and funding was provided by the USDA/Extension
Service/National Agricultural Pesticide Impact Assessment Program.
Pesticide
Information
Profile
TRADE OR OTHER NAMES
Chloropicrin
Some trade names for products containing chloropicrin include "Chlor-O- Pic,"'Metapicrm"'Timberfiune" and
"Tri-Clor." A partial list of trade names for chloropicrin mixtures with methyl bromide includes 'Tri-Con,"'Terr-
O-Gas,"'Preplant Soil Fumigant" and 'Pic-Brom." Chloropicrin mixtures with 1,3-Dichloropropene include
'Telone C-17,"'Tri-Farm" and 'Pic-Clor."
REGULATORY STATUS
Chloropicrin is currently undergoing USEPA FIFRA reregistration. It is a Class I toxicity, Restricted Use
Pesticide (RUP), labeled with the signal word 'Danger" (Q. The U.S. Department of Transportation (DOT)
proper shipping name is "Chloropicrin, 6.1, UN 1580, PGI, Poison Inhalation Hazard, Hazard Zone B." The
Emergency Response Guide (ERG) number is 56. NFPA designations are 4- Health, 0-Fire, 3-Reactivity.
Chloropicrin is not listed under the EPA Clean Air Act, EPA Clean Water Act or the EPA Marine Pollutant List
(2). A tolerance is not required for preplant soil fumigation uses ofchloropicrin.
INTRODUCTION
Chloropicrin is a clear, colorless, oily liquid with a strong, sharp, highly irritating odor. It is a strong lachrymator
W. Chloropicrin has been used as an insecticide since 1917 and as a soil finnigant since 1920 Q). The primary
use today is for preplant soil fiunigation to control soil borne fimgi, diseases and nematodes (1). It also is used to
treat wood poles and timbers for internal decay by fungi and insects; as a warning/clearing agent for sulfiuyl
fluoride (structural fumigant) and methyl bromide (soil and structural fiunigant); and is also used in organic
synthesis.
For soil finrugation and wood treatment, chloropicrin is packaged in DOT 4BW240 steel cylinders and bulk
tanks which may be pressurized. When used as a warning agent for methyl bromide, chloropicrin is packaged
along with the methyl bromide in steel cylinders. When used as a structural fumigation warning agent for sulfuryl
fluoride, chloropicrin is packaged in small plastic bottles in DOT approved overpacks.
Chloropicrin has a moderate vapor pressrire (18.3 mmHg at 20 degrees C) and exists as a I:Jquid at room

temperature. Chloropicrin/methyl bromide mixtures will volatilize readily upon opening of the cylinder valve.
Materials incompatible with chloropicrin are PVC, fiberglass, aluminum and magnesium and their alloys (1, 4}.
TOXICOLOGICAL EFFECTS
Acute Toxicity
Undiluted chloropicrin is highly toxic by ingestion or direct contact with the skin or eyes. According to the
American Conference of Governmental Industrial Hygienists (5), airborne exposure to 0.3-0.37 ppm (2-2.5
mg/meters cubed) for 3-30 seconds results in eye irritation.. This response is reported to be highly variable
among individuals and tearing (lachrymation) may occur at airborne exposures of 0.15-0.3 ppm (1-2 mg/meters
cubed) (5). Inhalation exposure to 4 ppm (26 mglmeters cubed) for a few seconds may cause some degree of
incapacitation (5) and an exposure of few seconds to 15 ppm (100 mg/meters cubed) can cause injury to the
respiratory track. Exposure to concentrations above 15 ppm can result in lacrimation, vomiting, and if allowed to
continue for a minute or longer, can cause pulmonary edema and possibly death (55). The American Industrial
Hygiene Association Emergency Response Planning Guideline for one hour exposure to chloropicrin is 3 ppm
(20 mg/meters cubed)().
Animal studies established that the 4-hour inhalation LC50 for chloropicrin vapor in rats is 11.9 ppm (79.7
mg/meters cubed)(22) and the respiratory irritation potential threshold (RD50) in mice is 7.98 ppm (53.5
mg/meters cubed){1}. The FIFRA Toxicity Classification for chloropicrm acute effects is Category I and the
signal word for that classification is `Danger."
Signs and Symptoms of Poisoning
Undihrted chloropicrin is severely and imrnediately irritating to the upper respiratory tract, eyes and skin upon
direct contact. Exposure to airborne concentrations of chloropicrin exceeding 0.15 ppm (1 mg/meters cubed)
can cause tearing and eye irritation which is reversible upon termination of exposure. Prolonged inhalation
exposures at airborne concentrations above 1 ppm may cause symptoms. of respiratory system damage including
irritation of the airways, shortness of breath and/or tightness in chest and difficulty in breathing. Inhalation
exposure to very high levels, even if brief can lead to pulmonary edema, unconsciousness and even death
CHRONIC TOXICITY
Subchronic Effects
Studies with male and female CD rats and CD-1 nice exposed to chloropicrin vapor in whole body inhalation
chambers at concentrations of 0.3, 1.0, or 3.0 ppm for six hours per day, five days per week for thirteen weeks
(2) and male Fisher 344 rats exposed to chloropicrin (8) indicated that respiratory tissue is the target for
chloropicrin inhalation toxicity. Portal- of -entry effects occurred in the upper respiratory tissue of animals inhaling
chloropicrin vapor for 90 days at concentrations at or above 0.1 ppm (0.67 mg/meters cubed).
Reproductive Effects
A study utilizing chlc, ropicrin vapor administered by whole body inhalation for six Hours per day, seven days per

week to male and female CD rats at concentrations of0.5, 1.0, or 1.5 ppm through two generations of animals
indicated that reproduction fitness is not adversely acted by chloropicrin inhalation even at systemically toxic
levels (2). The No Observable Adverse Effect Level (NOAEL) was 1.0 ppm for systemic toxicity and greater
than 1.5 ppm for developmental toxicity and reproductive parameters.
Teratogenic Effects
In a study with sexually mature virgin female Sprague-Dawley rats exposed by whole body inhalation to
chloropicrin vapor for six hours per day for days 6- l 5 of gestation, there were no treatment -related fetal
malformations (10). The incidence of developmental variations in the mid- and high -dose groups increased over
the control group and was statistically significant in the high -dose group. The NOAEL for maternal toxicity was
0.4 ppm and the NOAEL for fetal toxicity was 1.2 ppm indicating that the developing fetus is not a target tissue
for chloropicrin.
The developmental toxicity of chloro-picrin in sexually mature virgin female New Zealand White SPF rabbits was
evaluated by whole body exposure/inhalation to chloropicrin vapor for six hours per day for days 7-20 of
gestation (L I ). There were no treatment related fetal malformations reported, the incidence of developmental
variations in the mid- and high -dose groups was increased over the control group and was considered to be
treatment related but was not dose related nor was it statistically significant. The NOAEL for maternal toxicity
was 0.4 ppm and the NOAEL for fetal toxicity was 1.2 ppm indicating that the developing fetus is not a target
tissue.
Mutagenic Effects
Chloropicrin has been evaluated in several in vitro genetic toxicity test system (12, 15). Bacterial cell testing for
gene mutation produced some evidence of genetic toxicity in one of five tester strains in the presence of an
exogenous metabolic activation system but testing in higher order cells (mammalian cells) did not confirm the
potential for chloropicrin to produce gene mutation. Chloropicrin did not cause damage to mammalian cell DNA.
In vitro testing of mammalian cell chromosomes for damage (breaks, exchange figures, fragments, etc.) produced
evidence suggestive of clastogenic effect but the data were equivocal.
Carcinogenic Effects
Six long-term bioassays have been performed to evaluate the potential of chloropicrin to cause chronic and/or
carcinogenic effects by inhalation, oral, and gavage dosing (L 6, 20). Chronic toxicity was limited to inflammatory
and other degenerative changes associated with chronic wound healing at the portal -of -entry and at associated
tissues (ie. rodent forestomach following life-long oral dosing). No neoplastic or tumorigenic response was
produced by chloropicrin in any species tested by the three routes of exposure.
Organ Toxicity
Target organs for chloropicrin toxicity include eyes, skin, respiratory tract and tissue associated with portal -of -
entry into the body.
Fate in Mammals

A
The octanoVwater partition coefficient (Logl0 Kow) is 2.50 at 25 degrees C indicating that chloropicrin would
not be expected to bioaccumulate in mammalian cells Q).
ECOLOGICAL EFFECTS
Effects on Birds
Little information is available about the effects of chloropicrin on bird fife. A feeding study in chickens (22)
demonstrated no adverse effects at doses as high as 100 ppm for 120 days. This was the highest dose tested.
Effects on Aquatic Organisms
Chloropicrin is toxic to fish. For trout and bluegiil the 96-hour LC50 was 0.0I 65 mg/L and 0.105 mg(L
respectively (22).
Effects on Other Animals (Nontarget species)
When used according to label, exposure to nontarget species is unlikely. However, because of its toxicity to
mammals and invertebrates, it can be assumed that chloropicrin may be harmH to many nontarget organisms.
ENVIRONMENTAL FATE
Breakdown of Chemical in Soil and Groundwater
The half-life of chloropicrin in sandy loam soil was 8-24 hours (23) and 4.5 days (24) with carbon dioxide being
the terminal breakdown product (24). Chloropicrin moves rapidly in soils within twelve inches of injection but
may dime to a maxinuun depth of four feet in sandy soil (25). Since it is only slightly soluble in water, it will not
move rapidly in aquatic environments. In an anaerobic aquatic/soil systen-4 chloropicrin was converted to
nitrornethane with a half-life of 1.3 hours (26). In the absence ofsimlight or microorganisms, chloropicrin does
not undergo hydrolysis (22, 28). The calculated Henry's Law Constant is 2.51 x 10 to the minus 3 atm meters
cubed mole-1 (2). The Kee for silt loam and agricultural sand soils was 5.29 and 93.59 respectively (23).
Chloropicrin can be produced during chlorination of drinking water if nitrated organic contaminants are present
(M, 21). In a sampling of 1,386 wells in California between 1984 and 1989, no chloropicrin was detected (32).
In a sampling of 15,175 wells in Florida, chloropicrin was found in three wells at 0.035-0.068 Hg/L (32).
Breakdown of Chemical in Surface Water
Since chloropicrin has a higher density than water (1.65 g/ml) and is only slightly soluble, it will sink to the bottom
of surface water. The half- life of chloropicrin in water exposed to light was 31.1 hours with carbon dioxide,
bicarbonate, chloride, nitrate and nitrite being the breakdown products Q).
Breakdown of Chemical in Plants
No chloropicrin or nitrom,thane was detected in crops grown n soil treated with radiolabelled chloropicrin (L4).

Lr 1
Carbon dioxide, as the terminal breakdown product, was metabolized by plants and incorporated into natural
plant biochemical compounds via the single carbon pool (25).
Breakdown of Chemical in Air
Chloropicrin is efficiently photolyzed in the atmosphere. The half-life of chloropicrin in air exposed to simulated
sunlight was 20 days (36). The photoproducts were phosgene (which will hydrolyze to carbon dioxide and
hydrogen chloride), nitric oxide, chlorine, nitrogen dioxide and dinitrogen tetroxide.
Analytical Methods
The concentration of chloropicrin in air may be measured using Kitagawa direct reading gas detector tube#172
(Matheson-Kitagawa, East Rutherford, NJ). Gas chromatography methods are available to measure chloropicrin
in air (22) and may utilize XAD-4 solid sorbent tubes (SKC Inc., Eighty Four, PA).
PHYSICAL PROPERTIES AND GUIDELINES
Exposure Guidelines:
ACGIH TLV: 0.1 ppm TWA
OSHA PEL: 0.1 ppm
Physical Properties:
Appearance: Heavy, colorless, liquid with a sharp odor
Chemical names: Trichloronitromethane, Methane,trichloronitro; Nitrotrichloro-methane,
Nitrochloroform
CAS # 76-06-2
Molecular Formula: CC 13NO2
Molecular Weight: 164.38
Melting Point: -64 degrees C
Boiling Point: 112 degrees C
Vapor Pressure: 18.3 mmHg @ 20 degrees C, 24 mmHg @ 25 degrees C
Solubility in water: 1.6 g/L @ 25 degrees C
Solubility in other Miscible in most organic solvents.
solvents:
BASIC MANUFACTURERS
Niklor Chemical Corp.
2060 E. 220th Street
Long Beach, CA 90810

u
Review by Basic Manufacturer:
Comments solicited: May and October, 1995
Comments received: not received
REFERENCES
1. Meister, R.T. 1995. Farm Chemicals Handbook '95. Meister Publishing Company. Willoughby, OH.
2. Chemtox Online. 1995. Resource Consultants, Inc. Brentwood, TN.
3. Roark, R.C. 1934. USDA Miscellaneous Publication No. 176. A Bibliography of Chloropicrin 1848-
1932. United States Department of Agriculture. Washington, DC.
4. Thomson, W.T. 1991-2. Agricultural Chemicals Book III. Miscellaneous Agricultural Chemicals.
Thomson Publications Fresno, CA.
5. American Conference of Governmental Industrial Hygienists, 1992. Documentation of Threshold Limit
Values and Biological Exposure Indices, Sixth Ed. Cincinnati, pp. 299-300.
6. American Industrial Hygiene Association. 1987. Emergency Response Planning Guidelines. Chloropicrin.
AIHA, Washington, DC.
7, Chun, J.S. and W.J. Kintigh. 1993. Chloropicrin: Ninety -Day Inhalation Toxicology Study in Rats and
Mice. Bushy Run Research Center. Export, PA. (Unpublished study submitted to USEPA).
8. Yoshida, M. et. al. 1987. Subchronic Inhalation Toxicity of Chloropicrin Vapor in Rats. J. Pesticide Sci,
12:673-681,
9. Schardein, J.L. 1994. Two Generation Inhalation Reproduction/ Fertility Study in Rats. International
Research and Development Corp. Mattawan, MI. (Unpublished study submitted to USEPA)
10, Scharde4 J.L. 1993. Inhalation Developmental Toxicity Study in Rats. International Research and
Development Corp. Mattawan, MI. (Unpublished study submitted to USEPA)
11. Schardem, J.L. 1993. Inhalation Developmental Toxicity Study in New Zealand White Rabbits.
International Research and Development Corp. Mattawan, MI. (Unpublished study submitted to USEPA)
12. San, KH. and Valentine Wagner III. 1990. Sahnonella/Marnmalian- Microsome Plate Incorporation
Mutagenicity Assay (Ames Test) with a Confirmatory Assay. Microbiological Associates, Inc. Rockville
MD. (Unpublished study submitted to USEPA)
13. Putman, D.L. and Marcia Morris. 1990. Chromosome Aberrations in Chinese Hamster Ovary (CHO)
Cells With Confirmatory Assay. Microbiological Associates, Inc. Rockville, MD. (Unpublished study
submitted to USEPA)
14. San, R.H. and Cynthia Sigler. 1990. L5178Y TKO-/- Mouse Lymphoma Mutagenesis Assay With
Confirmation. Microbiological Associates, Inc. Rockville, MD. (Unpublished study submitted to USEPA)
15. Curren, R.D. 1990. Unscheduled DNA Synthesis in Rat Primary Hepatocytes With a Confirmatory
Assay, Microbiological Associates, Inc. Rockville, MD. (Unpublished study submitted to USEPA)
16. Ulrich, C.E. 1995. Two Year Oral (Gavage) Chromic Toxicity Study of Chloropicrin in Rats. International
Research and Development Corp. Mattawan, MI. (Unpublished study submitted to USEPA)
17. Wisler, J.A. 1994. Evaluation of Chloropicrin in a One Year Oral (Capsule) Toxicity Study in Dog.
International Research and Development Corp. Mattawan, MI. (Unpublished study submitted to USEPA)
18. Burleigh Flayer, H.D., W.J. Kintigh and C.L. Benson. 1995. Chloropicrin: Vapor Inhalation Oncogenicity
Study it CD- l Mice. Bushy Run Research Center. Export, PA. (Unpublished study submitted to
USEPA)
19. Burle igh- F layer, Y..D., W.J. Kintigh .ind C.L. Benson. 1995. Chloropicrn t: Vapor Inhalation Oncogenicity

Study in CD-1 Rats. Bushy Run Research Center. Export, PA. (Unpublished study submitted to USEPA)
20. National Institutes of Health. 1978. Bioassay of Chloropicrin for Possible Carcinogenicity. NCI Technical
Report No. 65, DHEW Publication No. (NIH) 78-1315.
21. Secara, S.R. 1990. Chloropicrin - Octanol/Water Partition Coefficient. Bolsa Research Associates Inc.
Hollister, CA. (Unpublished study submitted to USEPA)
22. United States Department of Agriculture Forest Service. 1986. Pesticide Background Statements.
Volume 11. Fungicides and Fumigants. Agriculture Handbook Number 661.
23. U.S. Environmental Protection Agency. 1992. Pesticide Environmental Fate One Line Summary:
Chloropicrin. USEPA Environmental Fate and Eff�cts Division. Washington, DC.
24. Shepler, K., C. Hatton and L. Ruzo. 1995. Aerobic Soil Metabolism of[14C]Chloropierin. PTRL West
Inc. Richmond, CA. (Unpublished study submitted to USEPA)
25. Ivancovich, A. 1987. Chloropicrin - Field Dissipation Study. Bolsa Research Associates. Hollister, CA.
(Unpub-fished study submitted to USEPA)
26, Shepler, K., C. Hatton and L. Ruzo. 1995. Anaerobic Aquatic Metabolism of[ 14C]Chloropicrim PTRL
West Inc. Richmond, CA. (Unpublished study submitted to USEPA)
27. Hazardous Substances Data Bank (HSDB). Accession Number 977. National Library of Medicine,'
Bethesda, MD. 1993 CD ROM version: Micromedix Inc., Denver CO.
28, Lee, H. and T. Moreno. 1993. Photohydrolysis of Chloropicrin. Bolsa Research Associates, Hollister,
CA. (Unpublished study submitted to USEPA)
29. Evaluation Summary, Ground Water Protection Data, Record No. 63408. 1989. California Department
of Food and Agriculture Pesticide Registration Branch.
30. Duguet, J.P., Y. Tsutsumi and A. Bruchet. 1988. Chloropicrin in Potable Water: Conditions of Formation
and Production During Treatment Processes. Environ. Technol. Lett. 9(4) 299-310.
31, Fair, P. S., R.C. Barth and J. Flesch. 1988. Measurement of Disinfection By -Products in Chlorinated
Drinking Water. Proc.- Water Qual. Technol. Conf:, 15:339-53. Office of Drinking Water, USEPA
Cincinnati, OH.
32. U.S. Environmental Protection Agency. 1992. Pesticides in Groundwater Database, A Compilation of
Monitoring Studies: 1971-1991, National Summary. EPA 734-12-92-0001.
33. Crain, E.M. 1985. An Adsorption Study With Soil and Chloropicrin. Wil Research Laboratories, Inc.
Ashland, OH. (Unpublished study submitted to USEPA)
34, Lawrence, L.J. 1990. Quantitative Characterization of [I 4C]Residues Present in Soil, Strawberries,
Green Beans and Red Beets Grown Under Actual Field Conditions Following Treatment of Soil with
[ 14C]Chloropicrin. PTRL East Inc., Richmond, KY. (Unpublished study submitted to USEPA)
35. Wilhelm, S. et. al. 1995. Environmental Fate of Chloropicr American Chemical Society Division of
Agrochemicals Picogram and Abstracts Vol 49.
36. Moilanen, K.W., D.G. Crosby and J. Humphrey. 1978. Vapor -Phase Photodecomposition of
Chloropicrin. Tetrahedron, 34, pp. 3345-3349.
37. Handbook of Environmental Data on Organic Chemicals. 1983. Verschueren Publishing Co. p. 384
Disclaimer: Please read the pesticide label prior to use. The information contained at this web site is not a
substitute for a pesticide label. Trade names used herein are for convenience only; no endorsement of
products is intended, nor is criticism of unnamed products implied. Most of this information is historical in
nature and may no longer be applicable.
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TOTAL ORGANIC HALIDES (TOX)
1.0 SCOPE AND APPLICATION
1.1 Method 9020 determines Total Organic Halides (TOX) as chloride in
drinking water and ground waters. The method uses carbon adsorption with a
microcoulometric-titration detector.
1.2 Method 9020 detects all organic halides containing chlorine,
bromine, and iodine that are adsorbed by granular activated carbon under the
conditions of the method. Fluorine -containing species are not determined by this
method.
1.3 Method 9020 is applicable to samples whose inorganic -halide concen-
tration does not exceed the organic -halide concentration by more than 20,000
times.
1.4 Method 9020 does not measure TOX of compounds adsorbed to
undissolved solids.
1.5 Method 9020 is restricted to use by, or under the supervision of,
analysts experienced in the operation of a pyrolysis/microcoulometer and in the
interpretation of the results.
1.6 This method is provided as a recommended procedure. It may be used
as a reference for comparing the suitability of other methods thought to be
appropriate for measurement of TOX (i.e „ by comparison of sensitivity, accuracy.
and precision of data).
2.0 SUMMARY OF METHOD
2.1 A sample of water that has been protected against the loss of
volatiles by the elimination of headspace in the sampling container, and that is
free of undissolved solids, is passed through 'a column containing 40 mg of
activated carbon. The column is washed to remove any trapped inorganic halides
and is then combusted to convert the adsorbed organohal ides to HX, which is
trapped and titrated electrolytically using a microcoulometric detector.
3.0 INTERFERENCES
3.1 Method interferences may be caused by contaminants, reagents,
glassware, and other sample -processing hardware.. All these materials must be
routinely demonstrated to be free from interferences under the conditions of the
analysis by running method blanks.
3.1.1 Glassware must be scrupulously cleaned. Clean all
glassware as soon as possible after use by treating with chromate cleaning
solution. This should be followed by detergent washing in hot water.
Rinse with tap water and distilled water and drain dry; glassware which is
not volumetric should, in addition, be heated in a muffle furnace at 400°C
CD-ROM 90203 - 1 Revision 2
September 1994

Id
for 15 to 30 min. (Volumetric ware should not be heated in a muffle
furnace.) Glassware should be sealed and stored in a clean environment
after drying and cooling to prevent any accumulation of dust or other
contaminants.
3.1.2 The use of high -purity reagents and gases helps to minimize
interference problems-,
3.2 Purity of the activated carbon must be verified before use. Only
carbon samples that register less than 1.000 ng C1-/40 mg should be used. The
stock of activated carbon should be stored in its granular form in a glass
container with a Teflon seal. Exposure to the air must be minimized, especially
during and after milling and sieving the activated carbon. No more than a 2-wk
supply should be prepared in advance. Protect carbon at all times from all
sources of halogenated organic vapors. Store prepared carbon and packed columns
in glass containers with Teflon seals.
3.3 Particulate matter will prevent the passage of the sample through
the adsorption column. Particulates must, therefore, be eliminated from the
sample. This must be done as gently as possible, with the least possible sample
manipulation, in order to minimize the loss of volatiles. It should also be
noted that the measured TOX will be biased by the exclusion of TOX from compounds
adsorbed onto the particulates. The following techniques may be used to remove
particulates; however, data users must be informed of the techniques used and
their possible effects on -the data. These techniques are listed in order of
preference:
3.3.1 Allow the particulates to settle in the sample container
and decant the supernatant liquid into the adsorption system.
3.3.2 Centrifuge sample and decant the supernatant liquid into
the adsorption system,
3.3.3 Measure Purgeable Organic Halides (PDX) of sample (see SW-
846 Method 9021) and Non-Purgeable Organic Halides (NPDX, that is, TOX of
sample that has been purged of volatiles) separately, where the NPDX
sample is centrifuged or filtered.
4.0 APPARATUS AND MATERIALS
4.1 Adsorption system (a schematic diagram of the adsorption system is
shown in Figure 1):
4.1.1 Adsorption module: Pressurized sample and nitrate -wash
reservoirs.
4.1.2 Adsorption columns: Pyrex, 5-cm-long x 6-mm-O.D. x
2-mm-I.D.
4.1.3 Granular activated carbon (GAC): Filtrasorb-400, Calgon-
APC or equivalent, ground or milled, and screened to a 1001200 mesh range.
Upon combustion of 40 mg of GAC, the apparent halide background should be
1,000 ng Cl" equivalent or less.
CD-ROM 9020B - 2 Revision 2
September 1994

4.1.4 Cerafelt (available from Johns -Manville) or equivalent:
Form this material into plugs to fit the adsorption module and to hold
40 mg of GAC in the adsorption columns.
CAUTION: Do not touch this material with your fingers. Oily residue
will contaminate carbon.
4.1.5 Column holders.
4.1.6 Class A volumetric flasks: 100-mL and 50-mL.
4.2 Analytical system:
4.2.1 Microcoulometric-titration system: Containing the
following components (a flowchart of the analytical system is shown in
Figure 2):
4.2.1.1 Boat sampler: Muffled at 800QC for at least 2-
4 min and cleaned of any residue by vacuuming after each run.
4.2.1.2 Pyrolysis furnace.
4.2.1.3 Microcoulometer with integrator.
4.2.1.4 Titration cell.
4.2.2 Recording device.
5.0 REAGENTS
5.1 Reagent grade chemicals shall be used in all tests. Unless
otherwise indicated, it is intended that all reagents shall conform to the
specifications of the Committee on Analytical Reagents of the American Chemical
Society, where such specifications are available. Other grades may be used,
provided it is first ascertained that the reagent is of sufficiently high purity
to permit its use without lessening the accuracy of the determination.
5.2 Reagent water. All references to water in this method refer to
reagent water, as defined in Chapter One.
5.3 Sodium sulfite (0.1 M), Na,S03: Dissolve 12.6 g ACS reagent grade
Na,S03 in reagent water and dilute to 1 L.
5.4 Concentrated nitric acid (HNO3).
5.5 Nitrate -wash solution (5,000 mg NO3_/L), KNO3: Prepare a nitrate -
wash solution by transferring approximately 8.2 g of potassium nitrate (KNO,)
into a 1-liter Class A volumetric flask and diluting to volume with reagent
water.
CD-ROM
5.6 Carbon dioxide (CO,): Gas, 99.9% purity.
5.7 Oxygen (OZ): 99.9% purity.
9020B - 3 Revision 2
September 1994

}
u
5.8 Nitrogen (NZ): Prepurified.
5.9 Acetic acid in water (70%) , C,H2O,: Dilute 7 volumes of glacial
acetic acid with 3 volumes of reagent water.
5.10 Trichlorophenol solution, stork (1 pL = 10 pg Cl-): Prepare a stock
solution by accurately weighing accurately 1.856 g of trichlorophenol into a 100-
mL Class A volumetric flask. Dilute to volume with methanol.
5.11 Trichlorophenol solution, calibration (1 pL = 500 ng Cl-), C,H,C130:
Dilute 5 mL of the trichlorophenol stock solution to 100 mL with methanol.
5.12 Trichlorophenol standard, instrument calibration: First, nitrate -
wash a single column packed with 40 mg of activated carbon, as instructed for
sample analysis, and then inject the column with 10 pL of the calibration
solution.
5.13 Trichlorophenol standard, adsorption efficiency (100 pg Cl-/liter):
Prepare an adsorption -efficiency standard by injecting 10 pL of stock solution
into 1 liter of reagent water.
5.14 Blank standard: The methanol used to prepare the calibration
standard should be used as the blank standard.
6.0 SAMPLE COLLECTION, PRESERVATION, AND HANDLING
6.1 All samples must be collected using a sampling plan that addresses
the considerations discussed in Chapter Nine.
6.2 All samples should be collected in bottles with Teflon septa (e.g.,
Pierce #12722 or equivalent) and be protected from light. If this is not
possible, use amber glass 250-mL bottles fitted with Teflon -lined caps. Foil may
be substituted for Teflon if the sample is not corrosive. Samples must be
preserved by acidification to pH <2 with sulfuric acid, stored at 4°C, and
protected against loss of volatiles by eliminating headspace in the container.
Samples should be analyzed within 28 days. The container must be washed and
muffled at 400°C before use, to minimize contamination.
6.3 All glassware must be dried prior to use according to the method
discussed in Sec. 3.1.1.
7.1 Sample preparation:
7.1.1 Special care should be taken in handling the sample in
order to minimize the loss of volatile organohalides. The adsorption
procedure should be performed simultaneously on duplicates.
7.1.2 Reduce residual chlorine by adding sulfite (5 mg sodium
sulfite crystals per liter of sample). Sulfite should be added at the
time of sampling if the analysis is meant to determine the TOX
CD-ROM 9020E - 4 Revision 2
September 1994

concentration at the time of sampling. It should be recognized that TOX
may increase on storage of the sample. Samples should be stored at 40C
without headspace.
7.2 Calibration:
7.2.1 Check the adsorption efficiency of each newly prepared
batch of carbon by analyzing 100 mL of the adsorption efficiency standard,
in duplicate, along with duplicates of the blank standard. The net
recovery should be within 10% of the standard value.
7.2.2 Nitrate -wash blanks (method blanks): Establish the
repeatability of the method background each day by first analyzing several
nitrate -wash blanks. Monitor this background by spacing nitrate -wash
blanks between each group of ten pyrolysis determinations. The nitrate -
wash blank values are obtained on single columns packed with40 mg of
activated carbon. Wash with the nitrate solution, as instructed for
sample analysis, and then pyrolyze the carbon.
7.2.3 Pyrolyze duplicate instrument -calibration -standards and the
blank standard each day before beginning sample analysis. The net
response to the calibration standard should be within 10% of the
calibration -standard value. Repeat analysis of the instrument -calibration
standard after each group of ten pyrolysis determinations and before
resuming sample analysis, and after cleaning or reconditioning the
titration cell or pyrolysis system.
7.3 Adsorption procedure:
7.3.1 Connect two columns in series, each containing 40 mg of
100/200-mesh activated carbon.
7.3.2 Fill the sample reservoir and pass a metered amount of
sample through the activated -carbon columns at a rate of approximately
3 mL/min.
NOTE: 100 mL of sample is the preferred volume for concentrations
of TOX between 5 and 500 pg/L, 50 mL for 501 to 1000 pg/L. and 25
mL for 1001 to 2000 pg/L. If the anticipated TOX is greater than
2000 pg/L, dilute the sample so that 100 mL will contain between
1 and 50 pg TOX.
7.3.3 Wash the columns -in -series with 2 mL of the 5,000-mg/L
nitrate solution at a rate of approximately 2 mL/min to displace inorganic
chloride ions.
7.4 Pyrolysis procedure:
7.4.1 The contents of each column are pyrolyzed separately.
After being rinsed with the nitrate solution, the columns should be
protected from the atmosphere and other sources of contamination until
ready for further analysis.
CD-ROM 9020B - 5 Revision 2
September 1994

7.4.2 Pyrolysis of the sample is accomplished in two stages. The
volatile components are pyrolyzed in a CO, -rich atmosphere at a low
temperature to ensure the conversion of brominated trihalomethanes to a
titratable species. The less volatile components are then pyrolyzed at a
high temperature in an 02-rich atmosphere.
7.4.3 Transfer the contents of each column to the quartz boat for
individual analysis.
7.4.4 Adjust gas flow according to manufacturer's directions.
7.4.5 Position the sample for 2 min in the 200'C zone of the
pyrolysis tube.
7.4.6 After 2 min, advance the boat into the 8000C zone (center)
of the pyrolysis furnace. This second and final stage of pyrolysis may
require from 6 to 10 min to complete.
7.5 Detection: The effluent gases are directly analyzed in the micro-
coulometric-titration cell. Carefully follow manual instructions for optimizing
cell performance.
7.6 Breakthrough: The unpredictable nature of the background bias
makes it especially difficult to recognize the extent of breakthrough of
organohalides from one column to another. All second -column measurements for a
properly operating system should not exceed 10% of the two -column total
measurement. If the 10% figure is exceeded, one of three events could have
happened: (1) the first column was overloaded and a legitimate measure of
breakthrough was obtained, in which case taking a smaller sample may be
necessary; (2) channeling or some other failure occurred, in which case the
sample may need to be rerun; or (3) a high random bias occurred, and the result
should be rejected and the sample rerun. Because it may not be possible to
determine which event occurred, a sample analysis should be repeated often enough
to gain confidence in results. As a general rule, any analysis that is rejected
should be repeated whenever a sample is available. In the event that repeated
analyses show that the seccnd-cclumn consistently exceeds the 10% figure and the
total is too low for the first column to be saturated and the inorganic Cl is
less than 20,000 times the organic chlorine value, then the result should be
reported, but the data user should be informed of the problem. If the second -
column measurement is equal to or less than the nitrate -wash blank value, the
second -column value should be disregarded.
CD-ROM 9020E - 6 Revision 2
September 1994

7.7 Calculations: TOX as Cl- is calculated using the following formula:
(C, - C3) + (Cz - C,)
where:
= pg/L Total Organic Halide
V
C, = pg Cl- on the first column in series;
CZ = pg Cl- on the second column in series;
C3 = predetermined, daily, average, method -blank value
(nitrate -wash blank for a 40-mg carbon column); and
V = the sample volume in liters.
8.0 QUALITY CONTROL
8.1 Refer to Chapter One for specific quality control guidelines.
8.2 This method requires that all samples be run in duplicate.
8.3 Employ a minimum of two blanks to establish the repeatability of
the method background, and monitor the background by spacing method blanks
between each group of eight analytical determinations.
. 8.4 After calibration, verify it with an independently prepared check
standard.
8.5 Run matrix spike between every 10 samples and bring it through the
entire sample preparation and analytical process.
9.0 METHOD PERFORMANCE
9.1 Under conditions of duplicate analysis, the method detection limit
is 10 pg/L.
9.2 Analyses of distilled water, uncontaminated ground water, and
ground water from RCRA waste management facilities spiked with volatile
chlorinated organics generally gave recoveries between 75-100% over the
concentration range 10-500 pg/L. Relative standard deviations were generally 20%
at concentrations greater than 25 pg/L. These data are shown in Tables 1 and 2.
10.0 REFERENCES
1. GasV ll, A., Compilation and Evaluation of RCRA Method Performance Data,
Work Assignment No. 2, EPA Contract No. 68-01-7075. September 1986.
CD-ROM 9020B - 7 Revision 2
September 1994

2. Stevens, A.A., R.C. Dressman, R.K. Sorrell, and H.J. Brass, Organic Halogen
Measurements: Current Uses and Future Prospects, Journal of the American Water
Works Association, pp. 146-154, April 1985.
3. Tate, C.. B. Chow, et al., EPA Method Study 32, Method 450.1, Total Organic
Halides (TOX), EPA/600/S4-85/080, NTIS: PB 86 136538/AS.
CD-ROM 9020B - 8 Revision 2
September 1994

TABLE 1. METHOD PERFORMANCE DATA'
TOX
Spiked
Concentration
Percent
Compound
Matrix'
(pg/L)
Recovery
Bromobenzene
D.W.
443
95
Bromodichloromethane
D.W
160
98
Bromoform
D.W.
160
110
Bromoform
D.W.
238
100
Bromoform
G.W.
10
140
Bromoform
G.W.
31
93
Bromoform
G.W.
100
120
Chloroform
D.W.
98
89
Chloroform
D.W.
112
94
Chloroform
G.W.
10
79
Chloroform
G.W.
30
76
Chloroform
G.W.
100
81
Dibromodichloromethane
D.W.
155
86
Dibromodichloromethane
D.W.
374
73
Tetrachloroethylene
G.W.
10
79
Tetrachloroethylene
G.W.
30
75
Tetrachloroethylene
G.W.
101
78
trans-Dichloroethylene
G.W.
10
84
trans-Dichloroethylene
G.W.
30
63
trans-Dichloroethylene
G.W.
98
60
'Results from Reference 2.
°G.W. = Ground Water.
D.W. = Distilled Water.
CD-ROM 9020B - 9 Revision 2
September 1994

TABLE 2. METHOD PERFORMANCE DATA'
Sample Unspiked Spike Percent
Matrix TOX Levels Level Recoveries
(pg/L)
Ground
Water
68.
69
100
98,
99
Ground
Water
5,
12
100
110,
110
Ground
Water
5,
10
100
95,
105
Ground
Water
54,
37
100
111,
106
Ground
Water
17,
15
100
98,
89
Ground
Water
11,
21
100
97,
89
'Results from Reference 3.
CD-ROM 9020B - 10 Revision 2
September 1994

Fig, 1, Schematic Diagram of Adsorption System
Nitrate wash
Reservoir
CD-ROM 9020B - 11 Revision 2
September 1994

Fig. 2. Flowchart of Analytical System
Sparging
Device
Titration Pyrolysis Boat
Cell Furnace Inlet
Adsorption
Module
Microcoulometer HRecorder
Strip Chart
with Integrator
CD-ROM 9020B - 12 Revision 2
September 1994

METHOD 9029E
TOTAL ORGANIC HALIDES (TOX)
START
7.1.1 T+k. .peolal I 7.3.2 Fall •. QPIo
ear■ in Mndling Irlk c•s•rveir; Pa•a Ilrk 1.9.9 hdjuat g+e
w le to m nimiae am le throv h !low
volatil.l le.. aeLiva t.d carbon
column.
7, 1.2 Add ,ulfita 7.4,5 P..it'art
to
reduce reudua1 7 3,3 Wa.h column• •ample _ 2
chlorine; akore et with .Lr:te nut.. rn 200 C
4 C rithouL .elution cone of pyroly,i.
he+d.q... tub.
7.2.1 CheoA
a beorp tacn
7 4 l Protect
7,4.6 Advanc. book
.traei.ncy Eor .ach
col umne from
into BOC C son•
batch of earhen
eoni..,nation
1.5 Ana Lyme
7.4.2 Pyrolya.
1 2.1 An.lyre
nitrate -wash bi+nk.
to .at.61i h
v I.Lila campan.ot.
in CO2-T ch
a[f lurnt g+.+r in
microceulometrle-
b.ekground
atmo.pMc. at Ie.
lrltatien Dell
t emP•ralut•
7.2.3 Pyralyr.
7.6 1.
dupLicale
7.{,2 Pyrolyae l..•
7.6 I. 2nd
2nd oelumn
in,trument
volatlle oonpounde
column Na
F•aaur•eent No
7 7 Cale.L.L■ TOX
eaI ibrtlien and
at high lamperatur.
ao+. cement ,10%
r < n tTat....h
a. Cl-
bl.nk a1a 1,rd■
to 02•rich
of 2 column
b1. 0
aaeh day
alm.. ph.,.
to to l'7
Ye,
Yam
7.7.1 Connect i
.eciu Lwc oelumn,
c ona
acta v+lad carbon
7.4 3 Tran,ac
0o Ianta f h 7 6 R•j•et and
alumrt to quad: eepeet
boat for analyaia
7.6 0iar.g+rd
...on
•co nd-oelumn •+lue STOP
CD-ROM 9020B - 13 Revision 2
September 1994

Chloropicrin
From W&Ocdia, the free encyclopedia
Chloropietin, also known as PS, is a chemical compound with the structural formula
C13CN02. This colourless highly toxic liquid was once used in chemical warfare and is
currently used as a fwnigam and nematocide.I2l[31
Contents
■ t History
■ 2 Preparation
■ 3 Properties
■ 4 Application
• 5 Safety
■ 6 Portrayal in Media
• 7 References
History
Chloropicrin was first discovered in 1848 by a Scottish chemist John Sicnhotuse. He
prepared it by the reaction of a chlorinating agent with picric acid:
HOC6H2(NO2)3 + 11 NaOCI --. 3 CI3CN02 + 3 Na,CO3 + 3 NaOH + 2
NaCI
Because of the precursor he used, Stenhouse named the compound chloropicrin,
although the two compounds are structurally dissimilar.
Arguably, chloropicrin's most famous use was in World War L In 1917, there were
reports that the Germans were testing and using a new chemical in warf lre.[4] That
chemical was chloropicri n, While not as lethal as other chemical weapons, it caused
vomiting and was a lachrymatory agent.01 This combination of properties forced Allied
soldiers to remove their masks to vomit, exposing them to toxic gases.r41 This caused a
large number of casualties on the Italian front.[41
Preparation
Chloropicrin is manufactured by the reaction ofnitromohane with sodium
hypochlorite:151
H3CN02+3 NaOCI C13CN02+3 NaOH
Properties
Chloropicrin
cl ,p
N+
C14—
)r4-
1UPAC name
i rich lorol n itrolmethane
Other names
Ps
Identifiers
CAS number
76.66-2'
ChentSpider
13861343'
UN17
14JTx7z7IJ2
KEW,
C18445'
ChCBI
CHEBI:39285'
Jmok3D images
Image l(httpl/chcmapps.stotaf.edu4moVjmoi.php?
model-CIC%2ACl%29%28C[%29%5BN%2l3%5D°/ 28°/ 5B0-
%5D%29%3DO)
SMILES
InChl
Properties
Molecular
formula
CC13NO2
Molar mass
164.375
Appearance
colorless liquid
Density
I.692 g/mlint
Melting point
-69 °C
Boiling point
112 °C (des)
Hazards
Main hazards Extremely toxic and "irritating to skin, eyes, and lungs.
(what is this?) (verify)
Except where noted otherwise, data arc given for materials in their standard
state (at 25 °C, 100 kPa)
]nfobox references
As listed in the Table, chloropicrirt is a colorless liquid that is insoluble in water, with which it is stable. With a vapor pressure of24 turn fig, its volatility is between
that of phosgene and mustard gas in persistency, although closer to phosgene because it is related to the conpound.161 Tests have shown that chloropkria causes
humans to shunt then eyex mvoluntarity.141 Chlnropicrin can be absorbed systemically thmugh inhalatiatt, ingestion, and the skin. It is severely irritating to the lungs,
eyes, and skin.1�1 Because ofthese properties, chloropicri t can only be delivered in shed form as a chemical weapon.[']
Application
Chloropicrin, today, is used as a titmigant to control pests round m the sojr2l Although less common, it can be used as a poison for vertebrates, such as rabbiSJ21
Chloropicrin is conannnty used in combination with other fitmigants, such as methyl bromide and sutlfiayl fluoride, for increased potency and as a warning agent.t2l
Chloropicrin has been used in chemical warfare. It first appeared in 1917 when the Germans tested a new chemical weapon on the Italian kontj61 The new chemical
weapon was devastating to the Allies at first, singe they had never encountered it before.
Safety
Chloropicrin is a highly+ toxic chemical: NIOSH 1995 states that;
0 C iloropicrin is a lac: imator rnd a severe i ritanl of the respiratory system in himw,Ls; it also causes sk vere sk,n ilritationn on conlutct. When splashed onto

the eye chloropicrin has caused ctimeal oedema and ligtllfieation of the cornea,
■ Exposure to concentrations of 15 ppm cannot he tolerated for more than I minute, and exposure to 4 ppm for a few seconds is temporarily disabling.
■ Exposure to 0.3-0.37 ppm chloropicrin for 3 to 30 seconds causes tearing and eye pain. Exposure to 15 ppm for a few seconds can cause respiratory
tract injury.
■ Exposure to ] l9 ppm in air for 30 minutes is lethal; death is caused by pulmonary oederm.
Hxamples of industrial exposure in humans: 27 workers in a cellulose factory who were exposed to high levels of chk)ropicrin for 3 ini nutes developed pneurnonitis
after 3 to 12 hours of irritated couotuug and difficulty on breathing; they subsequently developed pulmonary oederm, and one died.
FU classification ofehloropicrin is: R22 Harmful ifswallowed, R26 Very toxic by inhalation, R3613768 Irritating to eyes, skin and respiratory systems R43 May
cause se nskisation by skin contact, R50/53 Very toxic to aquatic organisms, may cause long term adverse effects in the aquatic environment.
Because ofchloropicrins stability, protection requires big* effective absorbents, such as activated charcoaLl41 Chbropicra tmklce its relative compound phosgene,
is absorbed readily at any temperature, which may pose a threat in low or high temperature cbmtes.161
The use ofthe substance has been restricted by the U.S. government, although such restriction is outdated now Isl
Portrayal in Media
In the 1987 Movie Dragnet, detectives Joe Friday (Dan Aykroyd) and Pep Streebeck (Tom Hanks) thwart an attempt by mad cuhsts to release a tanker truck of
trichloronitromethane at a party attended by several prominent Los Angeles city officials.
The effects cited in explaining the substance (vomiting, suffocation, and death) are consistent with the actual chenucaL
References
1. ^ httpV/msds.them,ox.ac.uk/CWchloropicrin.html
9 ^abed
httpJ/www.workcover.nsw.gov.au/Documents!Publications/AlertsGuidesFlazards/DangerousGoodsExplosivesF reworksPyrotechnics/chloropicrin_fact_sheet_1371.pdf
^ httpJlbooks.google.comlbooks?id—c'rMiiAAAAMAAI&pg=PAl44&dq=Chloropierin+in+chemical+warfare#PPAl44,M1
^ a b e d r j ht[pY/books.google. c onvbooks?id=eTA6AAAAMAAJ&pg=PA] 44&dq=Chloropic rin+in+chemical+warfare&c lieru-Fi refox-a# PPAI ",M I
^ Sheldon B. Markofsky "Nitro Compounds, Aliphatic" in Ullmann's Encyclopedia of Industrial Chemistry, Wiley -VCR Weinheim, 2005.
^ o b e d http)/botiks.google.com/books?id=eTA6AAAAMAAI&pg=PA144&dq=Chloropierin+in+chemical+wartare#PPA146.Mi
^ Chloropicrbt (PSI: Lung Damaging Agent (httpJlwww.cdc.gov/nioshlershdblEmergencyResponseCard_29750034.html) . National Institute for Occupational Safety
and Health. Emergency Response Safely and Health Database, August 22, 2008. Retrieved December 23, 2008.
^ Environmental Protection Agency. "Restricted Use Products (RUP) Report; Sic Month Summary Uist" (httpJ/www,epa.gov/opprdOOl/rup/rup6ntob.hinm)
httpllwww.epa gov/opprd001/rup/rup6muls.htm. Retrieved I December 2009.
Retrieved from"httpJlert.wikipedia.orglw/index.php?title=Chbropierin&oldid=444854343"
Categories: World War I chemical weapons I Fumigants I Ptdmonary agents I Lachrymatory agents I Vomiting agents I Nitromethanes
■ Tits page was last modified on 14 August 2011 at 20:15.
■ Texts available under the Creative Corramns Attnbutian-ShareAlmlce License; additional terms may apply. See Terror of use for details.
Wikipedia* is a registered trademark of the Wikitnedia Foundation, Inc., a non-profit organization

Chemt a�
�J
MATERIAL SAFETY DATA SHEET
MSDS Number: 00026
Product Name: Chloropicrin Industrial
Effective Date: 12/31/2005
Page: I of 7
SECTION I - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Product Name:
Chloropicrin Industrial
Supplier:
Chemtura USA Corporation
Address:
199 Benson Road City: Middlebury
State:
Connecticut 'Lip: 06749
Emergency Telephone Number: 1-800-949-5167
Information Telephone Number: 1-765-497-6100 Fax: [phone]
Chemtrec Phone:
1-800-424-9300; Internationally call 703-527-3887
Effective Date:
12/31/2005 Supercede Date: 03/24/2605
MSDS Prepared By:
Chemtura Product Safety Group
Synonyms:
Trichloronitromethane
Product Use:
Chemical Intermediate
Chemical Name:
Chloropicrin
Chemical Familv:
Halonitroalkane
Additional Information
Manufacturer:
Great Lakes Chemical Corporation, A Chemtura Company
P.O. Box 2200
West Lafayette, Indiana 47996-2200
SECTION II - COMPOSITION/INFORMATION ON INGREDIENTS
INGREDIENT NAME
CAS NO.
%
EXPOSURE LiM[TS
Chloropicrin
76062
97.5 min
Y (Hazardous)
0.1 ppm (OSHA PEL TWA)
Not established (OSHA PEL STEL)
Not established (OSHA PEL CELL)
0.1 ppm; A4 (ACGIH TLV TWA)
Not established (ACGIH TLV STEL)
Not established ACGIH TLV CEIL
*Indented chemicals are cam onents of previous ingredient.
Additional Information
OSHA IDHL = 4 ppm
NIOSH IDHL = 2 ppm
NIOSH REL = 0.1 ppm
EPA Fumigation Limit = 0.1 ppm
SECTION III - HAZARDS IDENTIFICATION
Emergency Overview: Colorless liquid
Intensely irritating tear gas odor
Highly toxic. May be fatal if inhaled.
Toxic. Harmful if swallowed.
Corrosive to eyes.
Corrosive to skin.
Causes severe respiratory tract, nose and throat irritation.
Mulagen
May cause heart effects.

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026
Product Name: Chloropicrin Industrial
Effective Date: 12/31 /2005
Page: 2 of 7
IL SECTION III - HAZARDS IDENTIFICATION
Bulk containers of chloropicrin are shock sensitive and can detonate.
Chloropicrin is not flammable, but may explode when involved in fires.
Relevant Routes of Exposure:
Ingestion, inhalation and skin absorption
Signs and Symptoms of Overexposure:
Chloropicrin is a powerful irritant with effects observed on all body surfaces.
Liquid chloropicrin is corrosive to skin. It causes severe watering of the eyes,
shortness of breath (pulmonary edema), dizziness, nausea and vomiting. Severe
exposure may cause weak and irregular heartbeat, asthmatic attack and may be
fatal. Skin wounds exposed to chloropicrin become septic.
Medical Conditions Generally
Aggravated By Exposure:
Dermatitis
Respiratory disorders
Potential Health Effects: See Section XI for additional information.
Eyes:
Corrosive to the eyes. May cause chemical burns.
Prolonged eye exposure may result in blindness.
Skin:
Corrosive to skin. May cause chemical burns,
Ingestion:
Toxic. Maybe harmful if swallowed.
Inhalation:
Causes severe mucous membrane and respiratory tract irritation. -
Can cause weak and irregular heartbeat.
Chronic Health Effects:
Can cause weak and irregular heartbeat,
Target organs may include the liver, kidneys, lungs, stomach, heart and skeletal
muscles.
Mutagen.
ACGIH has classified chloropicrin as an A4, Not Classifiable as a Human
Carcinogen.
Carcinoeenicity:
NTP: No
ACGIH: No
IARC: No
OTHER: No
OSHA: No
Additional Information
No information available
=SECT[4?�JV - FIRST AID MEASURES —3
Eyes:
In all cases of overexposure, get medical attention immediately. Take person to a
doctor or emergency treatment facility.
If in eyes, hold eyelids open and flush with steady gentle stream of water for at
least 15 minutes.
Skin:
In all cases of overexposure, get medical attention immediately. Take person to a
doctor or emergency treatment facility,
iron skin, immediately remove contaminated clothing, shoes, and other items
covering skin. Wash contaminated skin area thoroughly with soap and water,
Ingestion:
In all cases of overexposure, get medical attention immediately. Take person to a
doctor or emergency treatment facility.
Do not give anything by mouth to an unconscious person.
Inhalation:
lm all cases of overexposure, get medical attention immediately. Take person to a
doctor or emergency treatment facility.
If inhaled, get exposed person to fresh air, Keep warm. Make sure person can
breathe freely. If breathing has stopped, give artificial respiration, preferably
mouth-to-mouth.
Antidotes:
No information available
Notes to Physicians and/or Protection
for First-Aiders:
No information available
Additional Information
No information available

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026 Effective Date: 12/31/2005
Product Name: Chloropicrin Industrial Page: 3 of 7
SECTION V - FIRE FIGHTING MEASURES
Flammable Limits in Air (% by
Volume):
Not available
Flash Point:
Not combustible
Autoignition Temperature:
Not available
Extinguishing Media:
All conventional media are suitable.
Fire Fighting Instructions:
Wear a self-contained breathing apparatus and protective clothing to prevent skin
and eye contact in fire situations.
Unusual Fire and Explosion Hazards:
Under fire conditions, toxic and irritating fumes may be emitted.
Containers can explode in fire situations. Use water spray to cool containers
exposed to heat.
Heated material decomposes violently at 112 degrees C to severely toxic gases,
especially in contact with metals.
Flammability Classification: Non-combustible liquid
Known or Anticipated Hazardous
Products of Combustion: Hydrogen chloride and/or chlorine
Oxides of nitrogen
Phosgene
Carbon monoxide and carbon dioxide
Additional Information
No information available
SECTION VI - ACCIDENTAL RELEASE MEASURES
Accidental Release Measures: Evacuate immediate area of spill or leak. Use a NIOSH/MSHA approved self-
contained breathing apparatus and other appropriate personal protective
equipment for entry into affected area to correct problem. Move leaking or
damaged containers outdoors or to an isolated location, observing strict safety
precautions. Work upwind if possible. Allow spilled material'to evaporate or
absorb onto vermiculite, dry sand, earth or similar absorbent material which may
be disposed of on site, or at an approved disposal facility. Do not permit entry
into spill area or cleanup area by unprotected persons until concentration of
chloropicrin is determined to be less than 0.1 ppm.
Personal Precautions: See Section Vlll.
Environmental Precautions: No information available
Additional Information
A 5% sodium bisulfate solution may be used to wash spill area after pickup is complete to neutralize remaining chloropicrin.
Collect all rinsate for proper disposal.
SECTION VII - HANDLING AND STORAGE
Handling: Persons moving or handling containers should wear protective clothing. Open
container only in a well -ventilated area wearing protective clothing and
respiratory protection if necessary.
Avoid eye, skin and clothing contact.
Do not breathe mist or vapor.
Storage: Store in a cool, dry, well -ventilated area away from incompatible materials.
Keep away from direct sunlight.
Store away from heat, sparks, and flame.
Keep container tightly closed.
Other Precautions: No information available
Additional Information
No information available

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026 Effective Date: 12/31/2005
Product Name: Chloropicrin Industrial Page: 4 of 7
SECTION VIII - EXPOSURE CONTROLS/PERSONAL PROTECTION
Engineering Controls:
Adequate general ventilation is recommended when handling to control airborne
levels.
Ventilation Requirements:
Use local ventilation to keep levels below established threshold values. .
Use mechanical ventilation for general area control.
Personal Protective knuuil2ment:
Eye/Face Protection:
Chemical safety goggles or full face shield
Skin Protection:
Chemical resistant gloves with polyethylene liner
Clothing designed to minimize skin contact
Respiratory Protection:
Wear a NIOSH/MSi IA approved organic/acid gas cartridge respirator if misting
or vapor occurs, or there is potential for airborne exposures to exceed established
threshold values.
Consult the OSHA respiratory protection information located at 29CFR 1910.134
and the American National Standard Institute's Practices of Respiratory
Protection Z88.2.
Other Protective Clothing or
Equipment: Measure chloropicrin concentration with a Malheson-Kitagawa detection device
using tube 172.
Exposure Guidelines: See Section II.
Work Hvpienic Practices: Make sure piping is empty before doing maintenance work.
Additional Information
No information available
SECTION IX — PHYSICAL & CHEMICAL PROPERTIES
Appearance:
Colorless liquid
Percent Volatile:
Not available
Boiling Point:
233.6 degrees F, 112
pH Value:
Nat available
degrees C
Bulk Density:
Not available
pH Concentration:
Not available
Color:
Colorless
Physical State:
Liquid
Decomposition Temperature:
Not available
Reactivity in Water:
Not water reactive
Evaporation Rate:
Not available
Saturated Vapor
Concentration:
Not available
Freezing Point:
Not available
Softening Point:
Not available
Heat Value:
Not available
Solubility In Water:
0.2 g per 100 g of water
Melting Point:
-83 degrees F, -64 degrees
Specific Gravity or
C ,I
Density (Wafer=l ):
1.66
Molecular/Chemical Formula:
CC13NO2
Vapor Density:
—5.7
Molecular Weight:
NA
Vapor Pressure:
18.3 mmHg at 20 degrees C
OclanoVWater Partition Coefficient:
Not available
Viscosity:
Not available
Odor:
Intensely irritating tear gas
Volatile Organic
odor
Compounds:
Not available
Odor Threshold:
1.1 ppni
Water/Oil Distribution
Coefficient:
Not available
Particle Size:
Not available
We1Qht Per Gallon:
Not available
Additional Information
No information available
ILSECTION X - STABILITY AND REACTIVITY �I
Stability: Bulk containers are shock sensitive and can detonate, especially when heat is
available for initiation. Photodegradation producing phosgene is possible.
However, under ambient room light chloropicrin is stable to photodegradation.
Conditions to Avoid: Unstable under fire and extreme heat conditions.
Avoid direct sunlight.
Incompatibility With Other Materials:
Strong oxidizers

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026 Effective Date: 12/31/2005
Product Name: Chloropicrin Industrial
Page: 5 of 7
SECTION X - STABILITY AND REACTIVITY
Organic amines
Reducing agents
Sulfuric acid
Incompatible with containers or equipment made of aluminum, magnesium or
their alloys.
Aniline
3-Bromopropyne
Propargyl bromide
Sodium methoxide
Sodium hydroxide/alcohol solutions
Hazardous Decomposition Products:
Hazardous Polymerization:
Conditions to Avoid:
No information available
Thermal decomposition may produce the following:
Hydrogen chloride and/or chlorine
Oxides of nitrogen
Phosgene
Carbon monoxide and carbon dioxide
Will not occur
None
Additional Information
SECTION XI - TOXICOLOGICAL INFORMATION
VALUE LD50 OR LC50
ANIMAL
ROUTES
COMPONENTS
150 m/15 minutes
Rabbit
Acute Inhalation
Chloropicrin
11.9 m/4H
Rat
Acute Inhalation
Chloropicrin
4.2 mglkg
Guinea Pig
Acute Intravenous
Chloropicrin
25 mgfkg
Mouse
Acute Intra eritoneal
Chloropicrin
250 m
Rat
Acute Oral
Chloropicrin
Toxicological Information:
The inhalation LCLO for cats, rabbits and guinea pigs is 120 ppm for 20 minutes. The human TCLO is 298 ppm for 10
minutes. The oral TDLO in the mouse is 26,000 mg/kg/78 weeks.
Chloropicrin is corrosive to the skin and eyes and causes severe mucous membrane and upper respiratory tract irritation.
Inhalation can cause weak and irregular heartbeat, as well as ulceration of the olfactory epithelium and necrosis of the lung
tissues. Chronic stages of inhalation may produce marked necrosis of the kidney, liver and skeletal muscles.
In a two year oral chronic toxicity study in rats, at concentrations of 0.1, 1.0 and 10.0 mg/kg/day, hepatocyte vacuolation was
noted at all dose levels. In the 1.0 and 10.0 mg/kg/day dose levels epithelial hyperkeratosis of the nongiandular stomach was
noted in both males and females. A NOAEL was determined to be 0. l mg/kg/day. In another 90 day oral study in rats,
forestomach inflammation, necrosis, acantholysis, hyperkeratosis and ulceration were also observed. The NOAEL in this
study was determined to be 8 mg/kg.
This material was mutagenic in the Ames test. In lymphocyte cells, chloropicrin was found to induce sister chromatid
exchanges. _
Additional Information
No information available
SECTION XII - ECOLOGICAL INFORMATION
Ecological Information: 1.4250 (96 H) Fathead Minnow = 3.72 mg/L
LC50 (96 H) Rainbow Trout = 2.87 mg/L
LC50 (96 H) Bluegill = 2.82 mg/L

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026 Effective Date: 12/31/2005
Product Name: Chloropicrin Industrial Page: 6 of 7
11 SECTION XII - ECOLOGICAL INFORMATION 11
Chloropicrin will decompose in the environment. The photodegradation half life
is 20 days. Bioaccumulation in Fish is not expected. Acutely toxic to animals,
plants and aquatic organisms. Do not release to the environment.
Additional Information
No information available
SECTION XIII - DISPOSAL CONSIDERATIONS
Disposal Considerations: Dispose of waste at an approved chemical disposal facility in compliance with all
current Local, State/Province, Federal/Canadian laws and regulations.
Additional Information
Return empty cylinders freight collect to the Great Lakes Chemical Corporation location from which shipment was made.
Close cylinder valve by turning clockwise until hand tight. Disconnect lines. Replace safety caps and bonnet. Return partial
cylinders only after consulting Great Lakes Chemical Corporation for proper shipping instructions.
=SECTIONXIV - TRANSPORT INFORMATION
U.S. DOT
Proper Shipping Name: Chloropicrin
Hazard Class: 6.1 ID Number: UN1580
Packing Group: I Labels: Poison, Marine
Pollutant
Special Provisions:
See Below
Packaging Exceptions:
None
Non -Bulk Packaging:
227
Bulk Packaging:
244
Passenger Air/Rail Limit:
Forbidden
Air Cargo Limit:
Forbidden
Vessel Stowage:
D
Other Stowage:
40
Reportable Quantity:
NIA
AIR - ICAO OR IATA
Proper Shipping Name:
Forbidden
Hazard Class:
NIA
ID Number:
NIA
Subsidiary Risk:
NIA
Packing Group:
NIA
Hazard Labels:
NIA
Packing Instructions:
NIA
Air Passenger Limit Per Package:
NIA
Packing Instruction -
Cargo:
N/A
Air Cargo Limit Per Package.
NIA
Special Provisions Code:
NIA
WATER - IMDG _--
Proper Shipping Name:
Chloropicrin
Hazard Class:
6.1
ID Number:
UN1580
Packing Group:
I
Subsidiary Risk:
N/A
Medical First Aid Guide Code:
740
Additional Information
DOT Special Provisions: 2, B7, B9, B14, B32, B46, B74, T20, TP2, TP13, TP38, TP45
Poison Inhalation Hazard
Emergency Procedures Code: F-A, S-A
Marine Pollutant
SECTION XV - REGULATORY INFORMATION
U.S. Federal Regulations;
The components of this product are either on the TSCA Inventory or exempt (i.e. impurities, a polymer complying with the
exemption rule at 40 CFR 723.250) from the Inventory.
SARA 313
The following materials are subj,:ct to the reporting requirements of Section 313 of Title III of the Superfund Aniendmenis

MATERIAL SAFETY DATA SHEET
MSDS Number: 00026 Effective Date: 12/31 /2005
Product Name: Chloropicrin Industrial Page: 7 of 7
11 SECTION XV - REGULATORY INFORMATION 11
and Reauthorization Act of 1986 and 40 CFR Part 372:
Chloropicrin (De Minimis Concentration _= l%) _
State Regulations:
Massachusetts Substance List
New Jersey Right To Know Hazardous Substance List (I% reporting limit)
Pennsylvania Hazardous Substance List (1% reporting limit)
International Regulations:
This material (or each component) is listed on the following inventories:
Canada - DSL
EU - F,INECS
Japan - ENCS
Korea - ECL
Philippines - PICCS
Canadian Disclosure List (0.1%) - Chloropicrin
Canadian WHM1S Hazard Class and Division = D.l.a, F, F
SARA Hazards:
Acute: Chronic: Yes
Yes
Reactive: Yes Fire: No
Pressure: No
Additional Information
The above regulatory information represents only selected regulations and is not meant to be a complete list
SECTION XVI - OTHER INFORMATION
NFPA Codes:
Health:
4
Flammability:
0
Reactivity:
3
Other:
N
HMIS Codes:
* indicates chronic health hazard.
Health:
4*
Flammability:
0
Reactivity:
3
Protection:
X
Label Statements:
Not available
Other Information:
Abbreviations:
(L) = Loose bulk density in g/ml
LOEC = Lowest observed effect concentration
MATC = Maximum acceptable toxicant concentration
NA = Not available
N/A = Not applicable
NL = Not limited
NOAEL = No observable adverse effect level
NOEC = No observed effect concentration
NOEL = No observable effect level
NR = Not rated
(P) = Packed bulk density in g/ml
PNOR = Particulates Not Otherwise Regulated
PNOS = Particulates Not Otherwise Specified
REL = Recommended exposure limit
TS = Trade secret
Additional Information
Information on this form is furnished solely for the purpose of compliance with OSHA's Hazard Communication Standard,
29CFR 1910.1200 and the Canadian Iazardous Products Act and associated Controlled Products Regulations and shall not
be used for any other purpose.

. W,
TRI Search Results I Envirofacts I US EPA Page I of 4
Envirofacts
Search Results
9 TRI
Envirolacts Report
Query executed on SEP-28-2011
Results are based on data extracted on
Click on "View Facility Information" to view EPA Facility inlormaton for the facility.
TRI Links
Overvie
• S�erch
• s`tCdC
Gusto
. QW91
auide
• Stale Recoils
• TRI Explorer
• Data Element Search Tool
• Operator DoFinition
Model
�l'•^^C1o'111e
• TRI Proaram Home
Repor4
E rrn r
J
Facility Name: TRINITY MANUFACTURING INC Mailine Name: TRINITY MANUFACTURING INC
Address: 11 EV HOGAN DRHAMLET NC 283458821 Mailino Address: PO BOX 1519HAMLET NC 2B3451519
County; RICHMOND flggloll: 4
Facility Information: View Facility Information TRI ID: 28345TRNTYI I EVH DUNS Number4555424019
ERSIQ 110DO0349935
TRI Preferred Latitude:34.920833 TRI Preferred Lonoitude:79.670833
Public Contact: VICTOR PERREAULT Phone: [phone]
Parent Company: TRICAL INC Parent DUNS: 02871653D
Starting wlih Reporting Veer 20U6, TRI Facilities began reporting NAICS codes, Instead of SIC codes, to Identity their Primary Business Activities.
NAICS Codes for 2010
NAICS CODE
PRIMARY
NAICS DESCRIPTION
All Other Basic Organic Chemical Manufacturing
Alkalice. and Chlorine Manufacturing
325199
325181
YES
NO
The above Information comes from 2010, which was the last year NAICS code data was reported for this facility. The eerflest NAICS code data on Ills for this facility
was reported In 1992,
Gila tacJli
Map this facility using one of Envirofact's mapping utilities.
Besides TRI, this facility also does the following;
has reported air releases under the Clean Air Act
has permits to discharge to water
More information about these additional regulatory aspects of this facility can be found by pressing the other regulatory data button below.
Dftf.RegUIa10Fy.Dataj
http;//oaspub.ep".gov/eilviru/tris—control_v2.Lf-is_pi-int?tris_i(t=2834';TRNT)' 1 i EVH 9/ 18/201 1

TRI Search Results I Envirofacts I US EPA
Page 2 of 4
Total Aggregate Releases of TRI Chemicals to the Environment:
For all releases estimated as a range, the mid -point of the range was used in these calculations. This table summarizes the releases reported
by the facility. NR - signifies
nothing reported by this facility for the corresponding medium.
Total Aggregate Releases of TRI Chemicals excluding Dioxin and
Dloxln-Ilks Compounds
(Measured In Pounds)
Media 2010 2009 2008 20D7 2006 2D05 2004 2003
2002
2001
2000
1999
/998
1997
1996
1995
1994
1993
Air Emission 58.91 71-571 118.9 70 78 172 1257 681
632
656
569
543
699
637
547
760
5
1C
Surface Water Ullgharcea 0 0 0 0 0 0 0 0
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ggleases to Land 0 0 0 0 1 0 0 0 0
NR
0
0
NR
NR
NR
NR
NR
NR
NR
Underground Inl2g =1 NR NR NR NR NR NR NR NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total On -Site Releases 5&91 71.571 118.9 70 78 172 1257 681
632
656
569
543
699
637
547
700
5
1C
Transfer On -Site toDlaoasaE NR NR NR NR NR 0 0 0
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total Releases 58.91 71.571 118.9 70 78 172 1257 681
632
656
569
543
699
637
547
760
5
1C
Total Aggregate Releases of Dioxin and Dioxin -like Compounds
(Measured In Grams)
Media
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
1994
1993
AILEWsalone
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Surface Water Discharoes
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Releases to Land
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Undemround tnlection
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ToWOn-SiteReleases
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Transfer OR-SltetoOlsoasal
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total Releases
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
TRI Chemicals Reported on Form A. -
The facility has certified that for each chemical listed below, the annual release did not exceed 500 pounds for the reporting year listed and the listed chemicat was not
manufactured, processed. or otherwise used in an amount exceeding f million pounds in the reporting year. Form A can not be filed for PBT chemicals (except certain instances
of reporting lead in stainless steel, brass, or bronze alloys).
Chemical TRI 2010 2009 2008 2007 2006 2005 2004 2003 2002 2001 200D 1999 1998 1997 1996 1
Name Chemica
ID
SULFURIC 007664939 NR NR NR Reported Reported Reported Reported Reported Reported Reported Reported Reported Reported Reported NR P
ACID 11994
AND AFTER
:ACIQ
AEROSOLS"
ON LYI
VANADIUM N770 NR NR NR NR NR NR NR NR NR NR Reported NR Nil NR NA P
CAMP _VNOS
NOTE:
AN chemicals reported below have release or transfer amounts greater than zero. To see a list of all chemicals reported by this facility click Ifs'@.
Names and Amounts of Chemicals Released to the Environment by Year.
For all releases estimated as a range, the midpoint of the range was used in these calculations. NR - signifies nothing reported for this facility by the corresponding medium
Rows with all 'n" or "NR" vatues were not fisted.
httpaloaspte ,.cpa.� ew/enviroi(ris_colrtrlal_v2.uis_prise!?tris_id=-2g345TRNTYI 1 F"VH 912nr'2011

TRI Search Results I Envirofacts I US EPA
Chem[cal_Name
Media
Unit OI
2010 2009
2008
Measure
CHLORINE
Pounds
17.84
1.621
1.2
(TRI Chemical ID: 007782505)
FUG
CHLORINE
AIR
Pounds
27.2
39.42
0
(TRI Chemical ID: 0077B2505)
STACK
CHLOEQPICfilN
&M
Pounds
5.56
12.64
6.7
(TRI Chemical ID: 000076062)
EUQ
CHLOROPICRIN
Ajjg
Pounds
8.31
17.89
111
(TRI Chemical ID: UOD076062)
STACK
HYDROCHLORIC ACQ it 995
AB
Pounds
NA
NR
NR,
AND AFTER "ACID AEROSOLS"
j
ON LYl
(TR1 Chemical ID: 007647010)
SULFURIC ACID N994 AND
AB.
Pounds
NR
NR
NR
AFTER "ACID AEROSOLS"
FLI ,
ONLY)
(TRI Chemical ID: 007664939)
Page 3 of 4
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
1994
199
1
1
3
10
1
5
1
3
3
2
0
4
5
0
1
1
1
0
0
0
0
0
0
0
0
0
NR
0
0
3
158
315
67
80
56
1
14
630
$95
500
250
NR
N
68
73
10
932
593
547
599
565
526
67
42
32
250
NR
NI
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
2
250
NR
Ni
NR NR NR NR NR NR NR NR NR NR NR 5 5 5
J
Discharge of Chemicals into Streams or Bodies of Water:
Please note that either There were no releases of chemicals into streams or bodies of water reported by this facility or the facility did not file a TRI form R for the years 1987 to
2010. Rows with Refeaso Amount equal to 0" were nor listed.
Transfer of Chemicals to Oft -Site Locations other than POTWs:
Please Nore That there were no Transfer of Chemicals to Off -Site Locations other than POTWs. Rows with Total Transfer Amount equal to "0" were not listed
Summary of Waste Management Activities
Please note that chemical amounts shown here are not included in Total aggregate Releases shown above.
Summary of Waste Management Activities excluding Dioxin and Dioxin -like Compounds
(Measured In Pounds)
Year
On -Site
Ott -Site
On -Site
oil -sill
n• ite
011-Site
Total
c clin
Recycling
gneray Recovery
Enetroy Recovery
Treatment
Treatmen
Amou
2009
33036
0
0
0
171164
0
201D
40144
0
0
0
293739
D
2011 (Projected)
42151
0
0
0
308426
0
2012 (Projected}
44259
0
0
0
323848
0
Summary of Waste Management Activities for Dioxin and Dlaxlndike Compounds
(Measured In Grams)
This facility did not report any waste management activities for Dioxin and Dioxin -like Compounds.
Chemicals Under Waste Management:
Please note That chemical amounts shown here are nor included in the Total Aggregate Releases shown above. Transfers fe Publicly Owned Treatment Works are fisted on a
seperate table.
Chemical
Year
Unit Of
On -Site
off -sit a
On•Site
tt•Slte
On -Site
Ott -Site
To
Name
Recyclino
Recyclin
Enerov Recovery
Eneray_HerwylU
Trealed
Treated
Art
CHLORINE
2009
Pounds
0
0
0
0
171164
0
2010
Pounds
0
0
0
0
293479
0
2011 (Projected)
Pounds
0
0
0
0
30B153
0
2012 (Projected)
Pounds
0
0
0
0
323561
0
CHLOROPICRIN
2009
Pounds
33036
0
0
0
0
0
2010
Pounds
40144
a
0
0
260
0
2011 (Projected)
Pounds
42151
0
0
0
273
OI
hltp-//oia�nub.epa,V,c)v/envii"oftris_coi-i.Lrol_v.).tris_print'tris_d=.28345T1cNTYIIEVH 9/28/2011

TRI Search Results I Envirofacts I US EPA Page 4 of 4
I� 2012 (Projected) I Pounds I ^ 44259 01 01 0 287 01
Transfer of Chemicals to Publicly Owned Treatment Works (POTW):
This facility did not rransfarany chemicals to a Publicly Owned Trearment Works (POTW).
Non Production Releases:
This report shows the quantities of the chemicals released to the environment by reporting year as a result of remedial actions, catastrophic events, or other one-time events not
associated with production processes. Chemicals with zero release amounts are not shown.
Chemical Name
Reoortina Year
Unit 61 Measure
Release Ouantily
CHLORINE
2010
Pounds
CHLORINE
2008
Pounds
CHLORIN E
2005
Pounds
CHLORINE
2004
Pounds
QHLORINE
2002
Pounds
CHL090P ICRIN
2010
Pounds
CHLOROPICRIN
2009
Pountls
CHLOROPICBIN
2008
Pounds
CHLOROPIC RIN
2006
Pountls
CHLOROPIC RIN
2005
Pounds
CHI-QUOPICHIN
2004
Pounds
Additional links for TRI:
This information resource Is not maintained, managed, or owned by the Environmental Protection Agency (EPA) or the Envirolects Support Team. Neither the EPA nor the
Envirofacts Support Team a responsible for their content or site operation. The Envirolacts Warehousa provides this reference only as a convenience to our Internet users.
National Library of Medicine (NLM) TOXMAP IEKIT osoiaimeF, .
• The Environmental Defenso Fund's (ELF) Chemical Scorecard has online environmental information regarding this facilln,s rxn.oiscravmer.'reported TRI releases.
littp:lltl,ispub.cpii..ov/ciiviro/ti,i5_u(introl_,.v2.tris_pr:iit?tris_id=28345'71ZN'r),1 1 EVII 9/28/201 l

qmw-flvironmental Releases for TRINITY MFG. INC.
Page I of 4
Investigate POLLUTION LOCATORI Toxic Chemical Releases I Reports
Pollution Topics
►Toxic Chemical Releases
1 Lead Hazards
► 5uperfund
1 Smog and Particulates
► Hazardous Air Poltutants
► Clean Water Act
►Watershed indicators
►Animal Waste
► Community Canter
► En Espanol
► Chem icat Profiles
► Health Effects
► Reguialions
ZIP TO YOUR COMMUNITY
...................................I.........
I Go ►
SEARCH SCORECARD
Go /
Environmental Release Report: TRINITY MFG. INC.
Map Locating Toxic Chemical Releases
. 2002 Rankings: Major Chemical Releases or Waste
Generation at this Facility
. 2002 TRI Pollution Releases Ranked by Potential Human
Health Risks
2002 TRI Pollution Releases Sorted by Health Effect
What We Don't Know About Chemical Safety and Harm
+ TRI Data Summary
• Facility Information
Links
• Map Locating Toxic Chemical Releases
. TRINITYY MFG. INC., HAMLET, NC
tsse]
. 2002 Rankings: Major Chemical Releases or Waste Generation at This Facility*
Cleanest/Best Facilities in US Percentile Dirtiest/Worst Facilities in US
00/0 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Total environm,.ntal releases:
htti):/i'scorec:,rd.goocigll+de.colti/env-release.s/to.:ility.tcl'?hi_id=2X345TRN`1 Yl IEVH 9/28/2011

Environmental Releases for TRINITY MEG. INC.
Page 2 of
See how this facility ranks on other chemical release and waste management attributes tracked by
Scorecard
Rank facilities in NORTH CAROLINA or in RICHMOND County by chemical releases or waste generation
*Note: These rankings are based on chemical releases and transfers reported by industrial facilities to
the Toxics Release Inventory, and do not take into account major sources of pollution or toxic chemicals
that are not covered by TRI.
[t=I
• 2002 TRI Pollution Releases Sorted by Health Effect*
Air Releases
(Pounds from TRI
sources
Suspected Cardiovascular or Blood 5
Toxicants
Suspected Kidney Toxicants 5
Suspected Gastrointestinal or Liver 632
Toxicants
Suspected Neurotoxicants 632
Suspected Respiratory Toxicants 632
Suspected Skin or Sense Organ Toxicants 632
Water Releases
(Pounds from TRI
sources)
*Note: Some chemicals are associated with more than one health effect, so their release may be
counted multiple times in this table. Therefore, it is not appropriate to sum releases sorted by health
effect. Total reported releases to air and water are provided in the data summary below.
What We Don't Know About Chemical Safety and Harm
Air Releases
6 TRI chemicals released to air in the United States lack the risk assessment values required
For safety assessment
218 TRI chemicals released to air in the United States lack the exposure estimates required for
safety assessment
Water Releases
5 TRI chems released to water in the United States lack the risk assessment values required for
safety assessment
172 TRI chemicals released to water in the United States lack the exposure estimates required
for safety, assessment
TRI Data Summary
Environmental Releases, Transfers, and Production -Related Waste (Pounds from TRI sources)
Air
Water
Land
Underground
Total Environmental
Total Off -Site
Total Production -
Year
Releases
Releases
Releases
Infection
Releases
Transfers
Related Waste
1992
9
0
0
0
9
0
10
1993
10
0
0
0
10
0
8
1994
5
0
0
0
5
0
4
1995
760
0
0
0
760
0
681
1996
547
0
0
0
547
0
547
1997
637
0
0
0
637
0
637
1998
699
0
i,
0
699
0
699
http:/;sc:k,recai-d.good,,uiciL-.coral�nv-releases/racii:ty.teI?tri_9/28/2011

Wrivironmental Releases for TRINITY MFG. INC.
Page 3 of 4
1999
543
0
0
0
543
0
543
2000
569
0
0
0
569
0
71,233
2001
656
0
0
0
656
0
21,136
2002
632
0
0
0
62
0
26.216
"NA" means that no data are available because "Total -Production Related Waste" was not reported
until 1991.
Itoo I
Speak Out
3 Email EPA
_* Join an online discussion about this Facility
0 Join Together
_> Email a Scorecard Community Report to a friend
4 Network with environmental groups
Learn how to use Scorecard to find out about
toxics in your community
I�3P1
Support Us
4 Contribute to Environmental Defense
a Volunteer with environmental groups in your
community
. Facility_ Information
2002 Facility Name: TRINITY MFG. INC.
Mailing Address: 11 E.V. HOGAN DR., HAMLET, NC 28345
Public Contact: VICTOR J. PERREAULT
Phone:[phone]
SIC Code: 28 Chemicals And Allied Products
2002.Parent Company: TRICAL INC.
Latitude: 34.91694
Longitude: -79.67
Facilities are encouraged to respond to the information presented in Scorecard.
[tomI
Links
. See EPA Envirofacts report for this facility for information about regulatory compliance,
hazardous waste handling processes, Superfund status, and permitted air and water emissions.
• RTK NET report for this facility, which includes its complete Form R report to EPA's Toxics
Release Inventory
Scorecard's report for RICHMOND County on:
. Chemical releases from industrial facilities (TR_I)
• Hazardous air pollutants
. Criteri,. air pollutants
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Environmental Releases for TRINITY MFG. INC.
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CA201108800093
SOS I D: 0248196
BUSINESS CORPORATION Date Filed: 31291211I1 8:44:00 AM
7 Elaine F. Marshall
ANNUAL REPORT North Carolina Seeretary of State
CA201108800093
ME OF BUSINESS CORPORATION: Trinity hdanufacturing, Inc.
CAL YEAR ENDING. STATE OF INCORPORATION: DE
'-RETARY OF STATE CORPORATE ID NUMBER: 0248196
.TURF OF BUSINESS: mfg of specialty chemicals
RED AGENT: The Prentice -Hall Corporation Systents, Inc.
RED OFFICE MAILING ADDRESS: 327 Hillsborough St.
--- - --- •- --- - --Raleigh,-31�C 27602 - - - - — - _ ._ _ .....- - -- � _ _. —.__ _-
OFFICE STREET ADDRESS: 327 Hillsborough Street
Raleigh, IVC 27603 Wake County
ATURE OF ITIE NEW REGISTERED AGENT:
SIGNATURE CONSTITUTES CONSENT TO THE APPOINTMENT
[PAL OFFICE TELEPHONE NUMBER: [phone]
IPAL OFFICE MAILING ADDRESS: I I Ev Hogan Dr I PO Box 1519
Hamlet. NC 28345
AL OFFICE STREET ADDRESS: 11 Ev Hogan Dr
Hamlet, NC 28345
RINCLPAL OFFICERS:
ame: Viclor j perreattlt i9wo4& Nmne: Charles m davis wit
ride: Vice President Title: Vice President
Address: Address:
821 Sandcrest Drive 736 Seven Lakes North
vckin hwn, NC 28379 West End NC 27376
ERT1f-ICATION OF ANNU R T MUST BE COMPLETED BY ALL BUSINESS CORPORATIONS
FORM MUST BE SIGNED B N OFFICER OF THE CORPORATION DATE
iU b rJ- 'R-, rreau(� �Tyice%idw±
TYPE OR PRINT NAME TYPE OR PRINT TITLE
ANNUAL REPORT FEE: $25 MAIL TO: Secretary of State • Corporations Division • Post Office Box 29525 - Raleigh NC 27626-0525

9.. 9 : w
Nitromethane
From Wkipedia, the Free encyclopedia
Not to be confused with methyl nitrate.
Nitromethane is an organic compound with the
chemical formula CH3NO2. It is the simplest
organic nitro compound. It is a slightly viscous,
highly polar liquid commonly used as a solvent in
a variety of industrial applications such as in
extractions, as a reaction med" and as a
cleaning solvent. As an intermediate in organic
synthesis, it is used widely in the manufacture of
pharmaceuticals, pesticides, explosives, fibers,
and coatings. It is also used as a racing fuel in
Top Fuel drag racing, and as an important
component in the fuel for the miniature internal
combustion engines used, for example, in radio -
controlled models.
Contents
■ l Preparation
■ 2 Uses
■ 2.1 Derivatives
■ 2.2 As an engine fuel
■ 2.2.1
Explosive
properties
■ 3 Purification
■ 4 See also
■ 5 References
■ 6 External links
Preparation
Nitromethane is produced industrially by treating
propane with nitric acid at 350-450 °C (622-
842 T). 'This exothermic reaction produces the
four industrially significant nitroalkancs:
nitromethane, nitroethane, 1-nitropropane, and
2-nitropropane. The reaction involves free
radicals, including the alkoxyl radicals of the type
Nitromethane
H O-
H �\ '
H O
;
IUPAC name
nitromethane
Other names
nitrocarbol
Identifiers
CAS number
75-52-5 f
PubChern
6375
ChemSpider
6135 f
KEGG
C19275 x
ChEMBL
CHEMBL276924 f
RTECS number iPA9800000
]mol-31) images
Image 1
(httpJ/chemapps.stolaf.edu/jmoYjmol.php?
model—C%5BN%2B%5D%28%3 DO%29%5BO-
%5D)
SMILES
Inch[
Properties
Molecular
formula
CH3NO2
Molar mass
61.04 g/mol
Appearance
colorless liquid
Density
1.1371 g/cm3, liquid
Melting point
—29 °C (244.15 K)
Boiling point
100-103 °C (373-376 K)
Solubility in
water
ca. 10 g/100 mL
A� idity {pKa)
1 Q Z

CH3CH2CH2O, which arise via homolysis of the
corresponding nitrite ester. These alkoxy radicals
are susceptible to C—C fragmentation reactions,
which explains the formation of mixture of
products.[']
Although inexpensively available, nitromethane
can be prepared in other methods that are of
instructional value. The reaction of sodium
chloroacetate with sodium nitrite in aqueous
solution produces this compound:l2l
CICH2C00Na + NaNO2 + H2O
CH3NO2 + NaCl + NaHCO3
Uses
The principal use of nitromethane is as a
stabilizer for chlorinated solvents, which are used
in dry cleaning, semiconductor processing, and
degreasing. It is also used most effectively as a
solvent or dissolving agent for acrylate
monomers, such as cyanoacrylates (more
commonly known as "super-glue'�.1'1
Derivatives
In organic synthesis nitromethane is employed as
a one carbon building block.l31141 Its acidity
allows it to undergo deprotonation, enabling
condensation reactions analogous to those of
Viscosity
0.61 mPa-s at 25 °C
Hazards
MSDS
External MSDS
R-phrases
R5 Ri0 R22
S-phrases
S.I.J.
Main hazards
Flammable, harmful
NFPA 704
4
Flash point
35 °C
Related compounds
Related nitro
compounds
nitroethane
Related
compounds
methyl nitrite
methyl nitrate
Supplementary data page
Structure and
properties
n, Er, etc.
Thermodynamic
data
Phase behaviour
Solid, liquid, gas
Spectral data
UV, IR, NMR, MS
X (verify) (what is: �IX9)
Except where noted otherwise, data are given for materials in their
standard state (at 25 °C, 100 kPa)
Infobox references
carbonyl compounds. Thus, under base catalysis,
nitromethane adds to aldehydes in 1,2-addition in the nitroaldol reaction. Some important derivatives include the
pesticides Chloropicrin, C13CN02 and tris(hydroxymethyonitromethane, (HOCH2)3CN02. Reduction of the latter
gives tris(hydroxymethyl)aminomethane, (HOCH2)3CNH2, better known as " tris," a widely used buffer.
In more specialized organic synthesis, nitromethane serves as a Michael donor, adding to a,p-unsaturated carbonyl
compounds via 1,4-addition in the Michael reaction.
As an engine fuel
Nitromethane is used as a fuel in motor racing, particularly drag racing, as well as for rockets and model airplanes
and commonly referred to in this context as "nitro". The oxygen content of nitromethane enables it to bum with
much less atmospheric oxygen.
4CH3NO2 + 302 -, 4CO2 + 61120 + 2N2

14.7 lb (6.7 kg) of air is required to burn 1 lb (0.45 kg) of gasoline, but only 1.7 lb (0.77 kg) of air for 1 lb of
nitromethane. Since an engine's cylinder can only contain a limited amount of air on each stroke, 8.7 times more
nitromethane than gasoline can be burned in one stroke. Nitromethane, however, has a lower energy density:
Gasoline provides about 42---44 MJ/kg whereas nitromethane provides only 11.3 MJ/kg. This analysis indicates that
nitromethane generates about 2.3 times the power of gasoline when combined with a given amount of oxygen.
Nitromethane can also be used as a monopropellant, ie., a fuel that burns without added oxygen. The following
equation describes this process:
2 CH3NO2 --+ 2 CO + 2 H2O + H2 + N2
Nitromethane has a laminar combustion velocity of approx. 0.5 rn/s, somewhat higher than gasoline, thus making it
suitable for high speed engines. It also has a somewhat higher flame temperature of about 2,400 °C (4,350 °F).
The high heat of vaporization of 0.56 MJ/kg together with the high fuel flow provides significant cooling ofthe
incoming charge (about twice that of methanol), resulting in reasonably low temperatures.
Nitromethane is usually used with rich air/fuel mixtures because it provides power even in the absence of
atmospheric oxygen. When rich air/fuel mixtures are used, hydrogen and carbon monoxide are two of the
combustion products. These gases often ignite, sometimes spectacularly, as the normally very rich mixtures of the
still burning fuel exits the exhaust ports. Very rich mixtures are necessary to reduce the temperature of combustion
chamber hot parts in order to control pre-ignition and subsequent detonation. Operational details depend on the
particular mixture and engine characteristics.
A small amount of hydrazine blended in nitromethane can increase the power output even further. With
nitromethane, hydrazine forams an explosive salt that is again a monopropellant. This unstable mixture poses a severe
safety hazard, and is forbidden for use in model aircraft fuels.
In model aircraft and car glow fuel, the primary ingredient is generally methanol with some nitromethane (0% to
65%, but rarely over 30% since nitromethane is expensive compared to methanol) and 10-20% lubricants (usually
castor oil and/or synthetic oil). Even moderate amounts of nitromethane tend to increase the power created by the
engine (as the limiting factor is often the air intake), making the engine easier to tune (adjust for the proper air/fuel
ratio).
Explosive properties
Nitromethane was not known to be a high explosive until a railroad tanker car loaded with it exploded on June 1,
1958.151 After much testing it was realized that nitromethane was a more energetic high explosive than TNT,
although TNT has a higher velocity of detonation and brisance. Both of these explosives are oxygen poor and some
benefits are gained from mixing with an oxidizer, such as ammonium nitrate. Pure nitromethane is an insensitive
explosive with a Vol) of approximately 6,400 m/s (21,000 ft/s), but even so inhibitors may be used to reduce the
hazards. The tank car explosion was speculated to be due to adiabatic compression, a hazard common to all liquid
explosives. This is when small entrained air bubbles compress and superheat with rapid rises in pressure. It was
thought that an operator rapidly snapped shut a valve creating a 'hammer -lock' pressure surge. Nitromethane can
be sensitized by adding a base to raise the pH.
Nitromethane can also be mixed with ammonium nitrate, which is used as an oxidizer, to form an explosive mixture
known as ANNM. One graphic example of this was the use of nitromethane and ammonium nitrate in the
Oklahoma city bombing.

A' - I
It is also miscible with concentrated nitric acid, forming an explosive composition with similar power and sensitivity
to nitroglycerin.
Purification
Nitromethane is a popular solvent in organic and electroanalytical chemistry. It can be purified by cooling below its
freezing point, washing the solid with cold diethyl ether, followed by distillation.161
See also
■ Top Fuel
■ Adiabatic flame temperature, a thermodynamic calculation of the flame temperature of nitromethane
References
1. ^ a b Sheldon B. Markofsky "Nitro Compounds, Aliphatic" Ullmann's Encyclopedia of Industrial Chemistry 2002
by Wiley-VCH, Weinheim, 2002; doi:10.1002/14356007.a17_401
(httpJ/dx.doi.org/10.1002%2FI4356007.al7_4Ol) .
2. ^ F. C. Whitmore and Marion G. Whitmore (1941), "Nitromethane"
(httpJ/www.orgsyn.org/orgsyn/orgsyn/prepContent.asp?prep=cvlp0401) , Org. Synth.,
httpJ/www.orgsyn.org/orgsyn/orgsyn/prepContent.asp?prep=cvlp04ol; Coll. Vol. 1:401
3. ^ Hyp J. Dauben, Jr, Howard J. Ringold, Robert H. Wade, David L. Pearson, Arthur G. Anderson, Jr, Th. J. de
Boer, and H. J. Backer (1963), "Cycloheptanone" (httpJlwww.orgsyn.org/orgsyn/orgsyn/prepContent.asp?
prep=cv4p0221) , Org. Synth., httpl/www.orgsyn.org/orgsynlorgsyn/prepContent.asp?prep=cv4pO221; Coll. Vol.
4: 221
4. ^ Wayland E. Noland (1963), "2-Nitroethanol" (httpJlwww.orgsyn,org/orgsynlorgsyn/prepContent.asp?
prep=cv5p0833) , Org. Synth., httpJ/www.orgsyn.org/orgsyn/orgsyn/prepContent.asp?prep=cv5pO833; Coll. Vol.
4: 833
5. ^ Interstate Commerce Commission: Ex Parte No 213. "Accident Near Mt. Pulaski, ILL"
(httpa/www.blet602.org/Historic_accidents/Mt.%20Pulaski 6.1.1958.pdo
6. ^ Coetzee, J. R and Chang, T. H. (1986). "Recommended Methods for the Purification of Solvents and Tests for
Impurities: Nitromethane" (http)/www.iupac.org/publications/pac/1986/pdf/581lxl541.pdf) (PDF). PureAppl.
Chem. 58 (I 1): 1541-1545. doi:10. t351/pac 198658111541 (httpJ/dx.doi.org/10.1351%2Fpac 19865811154t) .
http)/www.iupac.org/publications/pac/1986/pdf/581 l xl541.pdf.
External links
WebBook page for nitromethane (httpV/webbook.nist.gov/cgvcbook.cgi?ID=C75525)
History of Nitromethane (httpJlwwwAragtimes.com/Nitromethane-Drag-Racing-Top-Fuel-Soup-of-
Choice.html)
Retrieved from'9ittpJ/erLwt7Cipedia.org/w/index.php?title=Nitromethane&oldid=455460500"
Categories: Nitromethanes I Nitro solvents I Fuels I Rocket fitels I Liquid explosives
Explosive chemicals I Fuel additives ( Drag racing I IARC Group 213 carcinogens
■ 'Phis page wa ; last inodified on t 4 October 2011 at 00:32.

■ Text is available under the Creative Cons Attribution-ShareAlike License; additional terms may
apply. See Terms of use for details.
WikipediaO is a registered trademark of the Wikimedia Foundation, Inc., a non-profit organization.

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Chloropicrin as a Soil Fumigant
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Stephen N. Wilhelm, Niklor Chemical Company, Inc., Chairman, Chloropicrin Manufacturers Task
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Force, Long Beach, CA 90810-1695.
° Manuscripts (TEKTRAN)
One soil fumigant being tested as a possible alternative for methyl bromide (MeBr) is already EPA
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registered, available, and practical to use. That compound is chloropicrin (CC13NO2). For over 75
o Datasets
years it has effectively controlled soil pests and pathogens utilizing proven cultivation methods.
Freedom of Information
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Chloropicrin was first tested as a prepiant soil fumigant in 1920. In 1957, fruit and vegetable
Reference Guide
production took a giant leap forward when a mixture of chloropicrin and methyl bromide
demonstrated remarkable synergism. Although straight chloropicrin is still applied today in severe
P F!eople&Places
soil -borne disease situations, it Is typically formulated with MeBr (20-33% chloropicrin) or with 1,3-
" „
t? News Evera ,.
dichloropropene (1,3-D).
&
e:erfn9
Chloropicrin (molecular weight 164.4) Is a small, single -carbon organic molecule that possesses the
�.
Carears
properties of rapid diffusion through agricultural soil and selective toxicity to common root
P?
destroying fungi. It is a clear, colorless, nonflammable liquid with a moderate vapor pressure (I8.3
mmHg at 68oF) and boiling point (234oF), Chloropicrin is unique because it is a strong lacrimator
(tear producer); therefore, it warns against potentially harmful exposure.
Chloropicrin is injected as a liquid Into the soil approximately 6-10 inches below the surface, 14
days or more before crop planting. It kills target fungi within 48 hours of application. Chloropicrin
also controls some root -destroying nematodes, soil Insects, and other plant -limiting pests.
The importance of soil fumigation in the control of plant pathogens cannot be overstated. Even in
agricultural soil with adequate nutrients, water and oxygen, plant growth and crop yields can decline
over time due to increasing levels of.pathogenic fungi and other pests. In the 1950s, before soil
fumigation with chloropicrin, California strawberry growers resorted to applying 500 pounds/acre or
more of nitrogen because of plummeting crop yields. The problem was not lack of soil nutrients --it
was lack of healthy roots. Strawberry root diseases were widespread at the time and the partially
rotted roots were not capable of absorbing the abundant nitrogen that was available. By making
high crop yields predictable and at the same time reducing the use of fertilizers, chloropicrin/MeBr
combinations have made It possible to replant the same fruit and vegetable land year after year.
Predictable crop yields have allowed breeders to concentrate their efforts on fruit quality,
appearance, and shipability.
Environmentally, chloropicrin does not have a significant ozone depletion potential because it
undergoes rapid breakdown in sunlight. It is metabolized in soil to carbon dioxide. Under
anaerobic/aquatic conditions, chloropicrin is converted to nitromethane within hours. In a plant
metabolism study utilizing soil treated with radiolabelled chloropicrin, no chloropicrin or
nitromethane was detected in any plant tissue or harvested produce.
The breakdown products of chloropicrin in soil (carbon dioxide, nitrate, chloride) are basic nutrients
not only for the plants but also for the microorganisms that inhabit crop soils. The extra salutary
effects over and above what would be anticipated from the control of target fungi alone on infested
soils are believed to result from the biological activity of root -friendly microorganisms that
recolonize the fumigated soil.
Since chloropic[ in is :,my slightly soh,ble in water (1.6 9/liter at '7oF) it will not move -apidly in

aquatic environments. I he hair -lire or cnloropicrm in water exposed to simulated sunlight was 31.1
hours with the final products being carbon dioxide, bicarbonate, chloride, nitrate and nitrite.
Chloropicrin does not undergo hydrolysis in the absence of sunlight.
The octanol/water partition coefficient (log,GKaw) for chloropicrin is 2.5, indicating that it will not
significantly bioaccumulate in animal cells. Chloropicrin did not induce cancer in six long-term
animal bioassays performed by inhalation, oral, and gavage dosing. Chronic toxicity was limited to
inflammatory and other degenerative changes associated with chronic wound healing at the site of
dosing (stomach, mouth, lungs). In some In vitro ('test tube') mutagenicity studies, chloropicrin
induced both negative and positive responses. In animal teratology studies via Inhalation, there
were no treatment -related fetal malformations. Reproductive fitness was not adversely affected in a
two-generatlon inhalation rat study.
Like most fumigants, chloropicrin is a Restricted Use Pesticide so its distribution and use are highly
controlled. Since it does not have the excellent herbicidal properties of McBr or the broad
nematocidal properties of 1,9-11), chloropicrin's use as an alternative will be in conjunction with 1,3-D
and compounds with broader herbicidal properties such as metam sodium, dazomet, and pebulate.
In the meantime, existing USEPA registrations that contain higher formulation ratios of chloropicrin
to McBr (i.e., 1:1, 1:1.3) than what Is typically applied today (1:2, 1:3) can be used. These
formulations will provide excellent soil pathogen and weed control without the need to alter current
proven cultivation methods.
[July 1926 Table of Contents] (Newsletter Issues Listingl LMethvl Bromi�a Home Pagel
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Columbia Analytical may or may not test for Chloropicrin (CAS 6 76m -e6-2). InforatWn is subject to change; please contact
us for the latest available analyzes for Won one test.
Columbia Analytical does not sell chemicals, but offers aralyticaI lab testing to determine the presence of vancue
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CI
Cf\\
Cl 0
Analyte: Chloropicrin
Alternate Name: Trichloronitromethane
Abbreviation: CHLOROPICAIN
CAS Number or ID: 76.06-2
Department: Organics
EC Number (EINECS): 76.06-2
Synonyms: Trichloronitr'orrethane;Methane, trichloronitro-;Acquinite;G
25;Larvacide;Microlysin;Nitrochloraform;Nitrotrichloromethane;Picfume;PS;S 1;Chloorpikhre;Chlor-o-
p1c;Chloroform, nitro -;Chloropicrine;Chlorpikrin;Cloropicrina;Dojyo picrin;Dolochlor,Methane, trichloronitro-,
(absorbed);Nemax; NC[-000533;Pic-Cfar;Picride;Tri-CIor,Trichloornitromethaa n;Trirhlornitromethan;Tricloro-
nitro-metano;Aquinite;Chloropicrin mixture;Klop;NA 1583;NA 1955;NA 2929;Profu
Chemical Formula: CCI3NO2
Apearance: oily colourless liquid
Melting Point: -69.2 C
Boiling Point: 112.4 C
Vapor Pressure: 16.9 mm Hg at 20 C
Water Solubility: 0.3 mg/100 ml at 22C
Stability: Stable. May decompose violently if heated. Large volumes of this chemical may be shock -sensitive.
Reacts violently with sodium methoxlder propargyl bromide and aniline. Incompatible with 3-bromopropyne,
strong oxidizers, plastics, rubber, Iron, zinc and other light metals,
<-- Search for more analytes
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Jones, Jennifer
From: Jones, Jennifer
Sent: Tuesday, January 24, 2012 9:46 AM
To: Brower, Connie; Chandler, Anne
Cc: Jones, Jennifer; Bennett, Bradley
Subject: RE: EPA test method 9020 - total organic halides
yes - that's exactly the problem - we want to know if there is chloropicrin, but i don't know if the test is appropriate and
will work for it (551). there shouldn't be any other chlorinated organics in there - and if there are its a problem either
way. So we have compromised on using the 9020, then if there are "hits" we'll try the 551 to see if its useful to verify.
Any other suggestions would be much appreciated, as I don't have training in these lab methods it makes it difficult to
make an informed decision about it - especially as the choices aren't very good.
Thanks!
Jen
From: Brower, Connie
Sent: Monday, January 23, 2012 2:19 PM
To: Jones, Jennifer; Chandler, Anne
Subject: RE: EPA test method 9020 - total organic halides
Jennifer —
In the end — Anne is the expert on the lab methods and as she has said, DWQ does not run this test. As I understand your
stormwater rules, no "certified" method is required, however, the big question for you is "what are you trying to
learn?" If you want to know specifically if chloropicrin is in the waste stream — Anne gave you the answer. Method 551
is more specific. However, as she also indicated, it may not be useful when analyzing a storm water sample. Why?
Because the method has been deemed applicable to processed water and raw source water. The matrix interferences
may be such that you will never see the chloropicrin, even if it is there. The other method may be more applicable to
the matrix — but, not tell you if you have the compound you are seeking...
Connie
From: Jones, Jennifer
Sent: Wednesday, January 18, 2012 12:54 PM
To: Chandler, Anne
Cc: Brower, Connie
Subject: RE: EPA test method 9020 - total organic halides
Hey Anne,
Thanks so much for this information. That's very helpful. I went to see Connie but she is at a meeting today. Connie —
when you get this can you give me a call please and tell me you opinion about these two tests?
Thanks!
Jennifer Jones
Environmental Engineer

NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: 'ennifer. ones ncdenr. ov
Website: htip:llportal.ncdenr.org/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Chandler, Anne
Sent: Tuesday, January 17, 2012 5.17 PM
To: Jones, Jennifer
Cc: Brower, Connie
Subject: RE: EPA test method 9020 - total organic halides
Jennifer,
I've never run either method or even dealt with the GC detector listed in Method 9020. Our lab here does not currently
have the capability to run either one, so the following information is just from reading the methods.
(1) 1 believe 551 would be easier and cheaper for most labs, as ECD detectors are usually more available and only
different extraction chemicals and standards would generally need to be purchased. Start up costs of new
methods may be necessary for either- ( Developing instrument methods, analytical curves, Method Detection
limits etc.)
(2) 9020 would be less specific and does not list Chloropicrin in the method compound list where as it is listed in
551. That is not to say you couldn't see it with 9020, I just don't have data to support that.
(3) Whether or not a method is appropriate for stormwater I'm not sure. The 551 method lists
Method 551
SCOPE AND APPLICATION
1.1 This methods-4 is applicable to the determination of the following analytes in
finished drinking water, drinking water during intermediate stages of treatment, and raw source water.
And we usually determine what method is used by EPA regulations or what the permits require.
(4) 1 would guess that Method 551 would be best analytically since Chloropicrin is listed in this method as a target
analyte, but 1 would not be the best person to say it is appropriate for stormwater or your purposes.
Below are links to both methods. I wish I was more familiar with them. 1-lave you talked to Connie Brower about
this issue? She may have some incite.
http://water.epa.gov/scitech/methods/ewa/bioindicators/upload/2007 Il 27 methods_method _551.pdf
http:l/www. epa.gov/epawaste/hazard/tcstmethods/sw846/pdfs/9020b. pdf
Organic Chemistry Branch Manager

Ann e.Chand IerC)ncden r.gov
NC DWQ Laboratory Section website: NCDENR - DWQ Lab
1623 Mail Service Center Phone [phone] x224
Raleigh, NC 27699-1623 Fax: [phone]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Jones, Jennifer
Sent: Tuesday, January 17, 2012 9:57 AM
To: Chandler, Anne
Cc: Jones, Jennifer
Subject: FW: EPA test method 9020 - total organic halides
Hey Anne,
I just had another conversation with the permittee on the topic of which test would be best for stormwater testing at a
chloropicrin manufacturing plant (apparently the only one in the US). As you know Chloropicrin is toxic to fish (and
humans) so we want to make sure that it is not present in their stormwater.
It sounds like from my research calling the labs that using 9020 might be easier and cheaper, but less specific. 551 is
specific, but used for drinking water. My questions are:
1) So you have any sense if 9020 would actually be cheaper and easier/more feasible for the lab?
2) Is 9020 less specific?
3) Is the drinking water test (551) an inappropriate test for stormwater, and if so, why? I'm not sure why some
test should be used for drinking water and some for stormwater and what the restrictions on those would be —
sorry I'm totally unfamiliar with these test methods and what the advantages/disadvantages of using them are!
4) Do you have a recommendation or any sense of which test might be more appropriate for a stormwater test?
Anyway, thanks so much for your help with this and I look forward to hearing back from you.
Thanks!
Jennifer Jones
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: htto://Portal.ncdenr.org/web/wq/­ws/­su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Schimizzi, Nikki
Sent: Tuesday, November 29, 2011 3:30 PM
To: Jones, Jennifer
Cc: Brower, Connie
Subject: FW: EPA test method 9020 - total organic halides
Hi Jen,
See Anne's response from the chemistry lab below regarding your question on test methods. I don't think that you were
copied (sorry for the duplicate if you already have this). I'm not sure if her email will help you or not. You can give her a
call directly if you want to have further clarification on the test methods. Connie and I don't have anything to add on
this question as it is out of our knowledge range (these are apparently not often used tests as it appears from Anne's
response that the chem lab doesn't have any experience with them either). Sorry that we couldn't be of more help.
Nikki
Please note new e-mail address: [e-mail]
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Chandler, Anne
Sent: Tuesday, November 22, 2011 3:35 PM
To: Schimizzi, Nikki
Subject: FW: EPA test method 9020 - total organic halides
Nikki,
Below is my reply to Connie. I meant to "reply to all".
Organic Chemistry Branch Manager
[e-mail]
NC DWQ Laboratory Section Website: NCDENR - DWQ Lab
1623 Mail Service Center Phone: [phone] x224
Raleigh, NC 27699-1623 Fax: [phone]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.

iJ
From: Chandler, Anne
Sent: Tuesday, November 22, 2011 3:33 PM
To: Brower, Connie
Subject: RE: EPA test method 9020 - total organic halides
Hi Connie,
We've never seen chloropicrin that we can remember. Yes, 551 is a drinking water method I believe. Below is from the first of
Method 9020, which of course we have no experience with.
I.1 Method 9020 determines Total Organic Halides (TOX) as chloride in
drinking water and ground waters. The method uses carbon adsorption with a
microcoulometric-titration detector.
1.2 Method 9020 detects all organic halides containing chlorine,
bromine, and iodine that are adsorbed by granular activated carbon under the
conditions of the method. Fluorine -containing species are not determined by this
1404C Z, &i�
Organic Chemistry Branch Manager
[e-mail]
NC DWQ Laboratory Section Website: NCDENR - DWQ Lab
1623 Mail Service Center Phone: [phone] x224
Raleigh, NC 27699-1623 Fax: [phone]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Brower, Connie
Sent: Tuesday, November 22, 2011 1:59 PM
To: Schimizzi, Nikki; Chandler, Anne
Subject: RE: EPA test method 9020 - total organic halides
Have you ever seen chloropicrin in the waters? And isn't 551 a drinking water method? I've been away too long...
Ahhh11 can I come back and bring my dear friend Nikki with me?
-c-
From: Schimizzi, Nikki
Sent: Tuesday, November 22, 2011 11:36 AM
To: Chandler, Anne
Cc: Brower, Connie; Jones, Jennifer
Subject: FW: EPA test method 9020 - total organic halides
Hi Anne,
Would you have any thoughts on the below question sent to us by Jennifer Jones in DWQ's stormwater permitting unit?
Connie and I didn't have a good response to this and thought it best to ask the experts!
Thank you!

Nikki
Please note new e-mail address: [e-mail]
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties. .
From: Jones, Jennifer
Sent: Tuesday, November 22, 2011 11:27 AM
To: Schimizzi, Nikki; Brower, Connie
Cc: Lawyer, Mike; Jones, Jennifer
Subject: EPA test method 9020 - total organic halides
Hi Nikki and Connie,
I am writing a permit for a facility that manufactures chloropicrin - http://en.wikipedia.org/wiki/_Chloropicri_n. It is a soil
fumigant used as a nematocide and fungicide. It also used to be used in chemical warfare. They also make bleach as a
by-product.
The facility told us that "there wasn't a test for chloropicrin" so I called two labs — Tritest and Prism.
• Tritest said they could test for it using EPA test method 551, but it might be a bit difficult, and they don't
routinely do it. That is a GC test.
Prism said that the nitro group can mess up the GC, and he'd recommend using EPA test 9020 — total organic
halides. This is a screen for the entire category of organic halides — of which chloropicrin is one of.
was not planning on adding a benchmark for chloropicrin or halides —just testing to see presence/absence. Would you
have a recommendation for one of these tests over the other (and why)?
Thanks ladies!
Jen
Jennifer Jones
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ![e-mail]
Website: htt ortal.ncdenr.or web w ws su

Jones, Jennifer
From: Karen Messana [[e-mail])
Sent: Monday, January 16, 2012 4:12 PM
To: Jones, Jennifer
Subject: RE: Trinity Draft Stormwater permit
Jennifer,
Could you give me a call when you have some time? I wanted to discuss someone I have learned about an EPA testing
method. Thanks, Karen
Karen Messana, CSP
EHS and Regulatory Compliance Manager
Trinity Manufacturing, Inc.
910-419-6566 direct
910-995-0843 cell
910-582-4433 fax
From: Jones, Jennifer[maiito:[e-mail]]
Sent: Tuesday, January 10, 2012 1:14 PM
To: Karen Messana
Cc: Lawyer, Mike; Jones, Jennifer
Subject: RE: Trinity Draft Stormwater permit
HI Karen,
Ok - that's not what they said when I spoke to them... I just reviewed my notes — I spoke with Steve Guptil at Prism (919-
818-1136). He's the one that recommended that halogens test. The lab does not technically need to be certified for the
test— but they do need to do it to the EPA standard (e.g. using the EPA standard exactly). Does that make sense?
If you can get me more info on 8270CD we can review it.
Thanks,
Jennifer Jones
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: iennifer.'[e-mail]
Website: http://portal.ncdenr.org/web/­wq/`ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Karen Messana[mailto:[e-mail]]
Sent: Tuesday, January 10, 2012 12:41 PM
To: ]ones, Jennifer
Subject: RE: Trinity Draft Stormwater permit

I spoke with Robb! at Prism yesterday. She said they could not do the test in-house and would use G Cal in Louisiana,
but thought they weren't certified in the method (I haven't verified that yet). She said the method is rarely used. I
spoke with Microbac and they couldn't do the test. I spoke with Meritech and below is the comment from Kris Pawlak,
Lab Manager:
01-09-1 2
Karen,
Method 9020B is a non-specific method detecting all forms of organic halides and thus in my opinion not a very
good choice in your case. We do not run that test in house but are familiar with the methodology. Method
8270CD is a better choice because it positively identifies the presence of chloropicrin. We do run this method in
house. Cost wise method 8270 is more expensive (about twice as much as 9020B) but if you only have to do it
quarterly or less often it should not be a problem.
We have also spoken with Test America and they recommended using the 8270CD test as well and they do not perform
the 9020B test.
I don't know if the 8270CD test identifies CP or not and I cannot find a copy of it on the internet, I am fixing to go travelling
the rest of the week. I will see what I can come up with regarding your question below about 8270CD. Thanks, Karen
Karen Messana, CSP
EHS and Regulatory Compliance Manager
Trinity Manufacturing, Inc.
910-419-6566 direct
910-995-0843 cell
910-582-4433 fax
From: Jones, Jennifer fmailto:[e-mail]
Sent: Tuesday, January 10, 2012 12:19 PM
To: Karen Messana
Cc: Lawyer, Mike; Jones, Jennifer
Subject: RE: Trinity Draft Stormwater permit
Hi Karen,
I spoke to Prism, TriTest and Microbac. I think it was Prism that said they could do that test. Their phone number is
[phone], or 704-529-6364. 1 would also try those other labs to see if they could do that as well. If that is not a
workable option, we'd be willing to consider using EPA method 8270C, if the methods are pertinent to what we want to
know and the test medium. Do you have any more information on it that you could give us?
Thanks Karen,
Jen
Jennifer Jones
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: lennifer.lones@ ncdenr.gov

Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Karen Messana fmailto:KMessana trinit rymfg.coml
Sent: Monday, January 09, 2012 10:59 AM
To: Jones, Jennifer
Subject: RE: Trinity Draft Stormwater permit
Jennifer,
In our draft permit, you are requiring the chloropicrin be tested using EPA method 9020B. Could you provide us the
name of a qualified lab that can do this? We have had no luck in finding a lab that is certified for that method. We have
found a lab that thought doing EPA method 8270C would work instead. Thanks, Karen
Karen Messana, CSP
EHS and Regulatory Compliance Manager .
Trinity Manufacturing, Inc.
910-419-6566 direct
910-995-0843 cell
910-582-4433 fax
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