The Avtex Saga: National Security versus ... - ACS Publications

Chemistry for Everyone

The Avtex Saga: National Security versus Environmental Protection Susan Groves and Frank Settle* Department of Chemistry, Washington and Lee University, Lexington, VA 24450; *[email protected]

The production of materials regarded as necessary for national security in World War II and the ensuing Cold War often came into conflict with environmental concerns and regulations. The most frequently cited example of this conflict is the manufacture of fissile materials for nuclear weapons in the Manhattan Project and subsequent endeavors (1). In this case the production of these materials took priority over environmental considerations, leaving a legacy of chemical and nuclear waste. However, the tension between national security interests and environmental concerns was not restricted to the production of nuclear weapons; it also created problems in the manufacture of less exotic materials. One example is the production of rayon at Front Royal, Virginia, which brought a series of politically powerful local employers manufacturing a product deemed necessary for the nation’s defense efforts into conflict with environmental regulations. The conflict began in the mid-1940s and ultimately resulted in closure of the plant in 1989. During this period, the manufacturing facility became Virginia’s largest Superfund site and in 1984, the nation’s second largest source of air pollution. The history of this controversy forms a fascinating case study that integrates scientific, economic, environmental, political, and legal issues surrounding the massive rayon plant on the picturesque Shenandoah River in the Blue Ridge Mountains (Fig. 1). After years of contention, cooperative efforts involving former plant owners, state and federal agencies, and local governments have emerged to clean up and convert the plant site into uses that enhance both the environment and the economy of the area.

high-tenacity rayon at the Front Royal plant. To increase the productivity of the Front Royal operation, the WPB financed the construction of auxiliary plants adjacent to the main rayon facility to synthesize two chemicals, sulfuric acid and carbon disulfide, that are required in large volume to produce rayon. The government retained ownership of both auxiliary plants. The carbon disulfide plant, built under contract by Stauffer Chemical Company, produced 26.4 million pounds of carbon disulfide per year. In October 1942, the need for rayon caused the WPB to obtain draft deferments for personnel working at the Front Royal plant, to direct other industry workers to the plant, and to provide housing for these additional workers. By 1944, the plant employed approximately 4,000 people and had produced 82 million pounds of rayon (2).

The Front Royal, Virginia, Rayon Plant in World War II

Figure 1. Location of the Avtex Superfund site.

In 1937, as the result of increasing demand for the popular synthetic fiber rayon,1 American Viscose Company, the U.S. branch of a British firm, Courtland’s Ltd., started construction of a large plant on the south fork of the Shenandoah River at Front Royal, Virginia. When this plant began to produce rayon, it was one of Virginia’s largest employers (Fig. 2). In 1941, Courtland’s’s sold the plant to American bankers2 “when England pledged its subsidiary’s stock to the U.S. government as part of a lend-lease agreement” (2) to generate funds for the war against Germany. The subsequent bombing of Pearl Harbor and the Japanese occupation of Southeast Asia had an immediate impact on the new Front Royal plant. This occupation cut off 90% of the natural rubber supply to the U.S. and created a need for high-tenacity rayon fiber for tire cord. This cord was necessary to strengthen and extend the life of synthetic rubber used in tires for the military. In 1942 the U.S. government, under the auspices of the recently formed War Production Board3 (WPB), ordered American Viscose to switch to the production of

Figure 2. The Avtex plant.

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The Viscose Process and Emerging Uses for Rayon Rayon is made by converting natural cellulose (see structure) into products that have more desirable properties. OH CH2

OH CH2

HO

O

HO

O

HO O

H O

HO

O

HO

OH

CH2

OH

OH

OH

n –2

Cellulose

The viscose process, a popular method of producing rayon, was discovered by two English chemists, Charles W. Cross and E. J. Bevan, in 1892 and patented by them three years later. This process (Fig. 3) involves dissolving the shorter fibers of natural cellulose in a strong base, transforming the cellulose into an ester, and then converting it into longer celluloid fibers of solid rayon. This is accomplished by first converting wood pulp or cotton linters4 into cellulose by reaction with sodium hydroxide to form alkali cellulose. The equation for the conversion of cellulose to viscose is shown below. S OH C

O

+ NaOH + CS2

C

C

S−

Na+

H H

Cellulose hydroxyl

Sodium xanthate (viscose)

Excess base is removed by a technique called “pressing” to loosen the crystalline structure of the cellulose. The alkali cellulose is then shredded to increase its surface area and allowed to age in air for two to three days before being reacted with gaseous carbon disulfide (CS2) to form cellulose xanthate, which is soluble in the basic solution. The resulting yellowish liquid, known as viscose, is aged, filtered, and degassed to remove bubbles that could weaken the filaments. The viscose liquid is then extruded through a spinneret or die into an acid bath containing sulfuric acid and a solution of glucose and zinc sulfate to prevent salt crystallization. As the streams of viscose enter the bath, the acid neutralizes the sodium hydroxide solution, breaks down the cellulose xanthate with emission of carbon disulfide, and precipitates the regenerated cellulose (rayon). The solid, longfibroid filaments or sheets of rayon are washed repeatedly; they then have sufficient strength to undergo the final winding or pressing operations without breaking.

Figure 3. Making rayon.

Production of one pound of rayon by the viscose process5 requires 1.2 pounds of wood pulp or cotton linters, 1.8 pounds of sulfuric acid, 1.4 pounds of sodium hydroxide, 0.5 pounds of glucose, 0.4 pounds of carbon disulfide, 0.4 pounds of other chemicals, and 175.0 gallons of treated water. Many of these substances are toxic and pose a threat to both workers’ health and the environment. (Table 1 gives the Web sites for the materials safety data sheets for the chemicals necessary for the production of rayon.) An annual output of two million pounds of rayon requires one million gallons of treated water per day. This requirement for large amounts of water was a major factor in the location of rayon plants. Most plants had facilities to soften the water and to produce most of the electricity required for operation. During World War II, rayon was used not only for tire cord, but also in parachutes, belts, uniforms, electrical insulation, and decontamination garments. In 1948, Michelin in France developed the radial tire that used both rayon and nylon as cord material. Radial tires were first sold in the USA in 1965 and soon came into wide use. In the mid-1960s a process to convert rayon into carbon/graphite fibers was patented, and this carbonized rayon (3) formed the basis of composite materials used in a variety of products such as rocket nozzles, tennis rackets, and boat hulls.

Table 1. Web Sites for MSDSs on Chemicals Used in Rayon Production Chemical

URL (all accessed Feb 2002)

Carbon disulfide

http://www.mathesongas.com/msds/CarbonDisulfide.htm

Sulfuric acid

http://www.trainingsystemsinc.com/odm/msds0005.htm

Zinc hydroxide

http://www.ameroncoatings.com/coatings/msds_test/3207B70046.htm

Sodium hydroxide

http://www.hummelcroton.com/m_naoh.html

Zinc sulfate

http://www.oldbridgechem.com/msdsznso4.html

NOTE: The Jump Web site’s MSDS Directory provides information on more than 264,000 industrial products, including the full MSDSs, at http://www.1jump.com/msds-directory.html.

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Environmental Problems Emerge As World War II ended, people in the Front Royal area had time to return to fishing and hunting, and when they did, they began to notice that the Shenandoah River was polluted. A group of sportsmen, upset about the pollution of the river, called upon the Virginia General Assembly to address the issue. The General Assembly responded by forming the Virginia Water Control Board (VWCB) in 1946 under the Department of Environmental Quality (DEQ). The VWCB began regulating the disposal of wastes and by-products of industries such as American Viscose. In 1948, the VWCB ordered American Viscose to build a waste-water treatment plant at a cost of $150,000 to neutralize sulfuric acid. By 1949, the plant owners felt that they had addressed the problem of pollution, specifically zinc pollution, in the river and said “serious contamination no longer exists”. This opinion was not shared by regulatory agencies such as the U.S. Fish and Wildlife Service (4 ). A spectacular fire at the Front Royal Plant in 1955 resulted in $1 million damages but no injuries. In 1959 pollution from the plant caused a major kill of approximately 500,000 fish along 35 miles of the river. With the addition of a new provision to the State Water Control Law, the VWCB was able to fine American Viscose $154,770 for the costs of restocking fish in that section of the river (4 ).

Changes in Ownership of the Plant and Continuing Environmental Problems Despite these fines and setbacks, American Viscose was operating at a profit in 1963 when it was sold to FMC, a large corporation headquartered in Chicago. FMC Corporation operated the plant for 13 years until it was purchased by Avtex Fibers as part of a $200 million leveraged buyout6 in 1976 (4 ). At the time of purchase, the plant was operating at a loss due to a decreased demand for rayon, but Avtex was able to use the plant as collateral to obtain loans for the takeover. A loan from the New England Life Insurance Company guaranteed by the Federal Housing Administration (FHA) allowed Avtex to obtain the Front Royal plant for $750,000. However, FMC Corporation retained ownership of the wastewater treatment facility. Environmental problems continued under Avtex management. In 1980 the VWCB cited the plant for ground water contamination from 23 unlined surface impoundments containing toxic waste. The consequences of the plant’s operations became obvious when carbon disulfide, a toxic waste from the viscose process, was found in the wells of a subdivision across the river from the plant in 1982. After a regional engineer for VWCB questioned why such a large percentage of the people in the area were purchasing watertreatment systems for their wells, the VWCB decided to test the wells of the surrounding neighborhoods. These tests revealed light brown or yellow water that smelled of sulfur. When asked why they did not inform officials about the quality of their water, the workers responded that being employed and providing for their families were more important than their concerns about the environment or the community’s health (5). In 1983 and 1984, Avtex purchased 23 residential properties and installed ground-water pumping systems. Cadmium, lead, hydrogen disulfide, and arsenic, in addition to carbon disulfide, were found in the ground water.

Figure 4. The Avtex plant becomes a Superfund site.

The EPA Becomes Involved The U.S. Environmental Protection Agency (EPA), created in December 1970, joined the VWCB in litigating the environmental hazards at the plant. In 1980, Congress passed the Comprehensive Environmental Response, Compensation and Liability Act (known as Superfund) administered by the EPA to clean up hazardous waste sites designated by a National Priorities List. In 1984, the EPA nominated the plant at Front Royal for designation as a Superfund site, and after more citations of acute toxicity in the water on the site, the plant was designated in 1986 as Virginia’s largest Superfund site (Fig. 4) (4 ). Along with the environment, the health and safety of the workers were also suffering. The plant came under close scrutiny after three deaths within two months in 1986. In April 1986, an Avtex employee was blinded in one eye after being splashed with the alkaline solution used in the viscose process. The Virginia Department of Labor subsequently suggested a comprehensive plant inspection. In November of the same year, an Avtex department head was killed in the implosion of an acid evaporator. Avtex was fined $900. Later in November, a forklift operator was struck by a bale of pulp and killed. This death was attributed to worker error and no citation was issued. However, in the next month, an Avtex shift supervisor working in an empty acid tank was killed by inhalation of carbon disulfide and hydrogen sulfide. The Labor Department fined Avtex $2,160 for failure to provide workers with respirators and for other safety violations (6 ). Finally, a three-month investigation by the Virginia Department of Labor, ending in June 1987, uncovered 1,921 violations of standards for worker safety and 92 violations of standards for worker health. In the midst of this investigation, the union workers, whose livelihoods depended upon their jobs at Avtex, agreed to a $1/hour pay cut to keep the plant operating. Avtex and National Security The Avtex operation was crumbling in more ways than one. In 1987, structural deterioration led to the collapse of a portion of the plant’s roof. In 1988, after more than 1,700 violations of its waste discharge permit, Virginia Attorney General Mary Sue Terry threatened Avtex with a multimillion dollar lawsuit for water pollution and worker safety violations (7). This caused Avtex chairman and principal stockholder John N. Gregg (previously an FMC Fibers division vice president) to play his trump card. Avtex was the sole supplier of carbonized rayon that was used as a component in rocket nozzles by the U.S. Air Force and the National Aeronautics and Space Administration (NASA). As pressure to close the


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plant mounted, Gregg announced plans to shift to the production of carbonized rayon used in heat resistant composite materials for military rockets and the Space Shuttle (8). When the Virginia Attorney General’s office filed a $19.7 million lawsuit against Avtex on November 2, 1988, Gregg closed the plant the next day. At a press conference held at the plant’s closing, Gregg reminded the audience that “Avtex is the only company in the world that produces the carbonized rayon yarn used by the Air Force and the National Aeronautics and Space Administration to insulate rocket nozzles. What we need is support from space and military and we’re not getting it” (6 ). At the height of the Cold War, this was a powerful argument for the continued operation of the Front Royal plant. After a meeting with representatives from the Department of Defense, NASA, EPA, the Department of Justice, the Department of Transportation, and involved state agencies, Senator John Warner of Virginia said, “It is essential to our national security to keep this plant operating” (5). The support came a week later. The plant was reopened on November 10 after Warner helped secure $43 million in contracts from NASA and the Air Force to bail out Avtex. Avtex and the Community At its peak, Avtex employed more than 1,300 workers, a majority of whom were residents of the Front Royal area. Thus, Avtex’s financial problems had a great impact on the economy of the community. Foremost among these problems were the fines resulting from environmental and safety violations. Second was the physical deterioration of the plant, which affected operations and reduced productivity. Third, the VWCB and EPA’s orders to build new waste disposal systems and the imposition of regulations regarding exposure of workers to hazardous chemicals required additional expenditures. Finally, there was a decrease in the demand for rayon owing to its replacement in commercial products by other synthetic fibers7 and because a larger portion of manufactured fibers, including rayon, was being produced outside the USA.8 In a November 20, 1988, article, Joseph Gatins, a reporter for the Richmond Times Dispatch, wrote that 13,125 jobs in the surrounding communities could be indirectly affected by lowering the standard for workers’ exposure to carbon disulfide gas from the current value of 20 ppm to the required 1 ppm. Furthermore, the workers strongly defended Avtex because of their dependence on the company for their livelihood. “‘We’ve got to eat first,’ said David Ramsey, secretary of Local 371T of the Amalgamated Clothing and Textile Workers. ‘We’ll die second’” (4 ). The workers were angry with the Virginia Attorney General for the suit against Avtex and the resulting plant closure (9). No one, though, could deny the effects of the pollution from the rayon plant and the plant’s inability to curb the output of harmful chemicals. In December 1988, it appeared that Avtex and the state of Virginia had reached an agreement that would bring harmful emissions under control and begin to clean up waste on the site. The state agreed to drop enforcement actions in return for a pledge from Avtex to spend $5.7 million on cleanup activities and to pay $2 million in civil penalties over the next six years (10).

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Closure of the Plant Events leading to the final closure of the plant happened rapidly in 1989. In April additional violations and polychlorinated biphenyl9 (PCB) contamination of the river were discovered. In May, the VWCB warned the populace that the fish from the Shenandoah River were contaminated with PCBs and should not be eaten. In addition, the DEQ reported there was still ground-water contamination from carbon disulfide, phenol, sodium, and heavy metals including lead, arsenic, and cadmium, and soil contamination from carbon disulfide, phenol, arsenic, lead, and PCBs. June brought an EPA citation of the plant as the nation’s second largest air polluter and an order for Avtex and FMC Corporation to begin remedial activities within 60 days. Also during this month, the Virginia Air Pollution Control Board ordered Avtex to reduce its carbon disulfide emissions. As a result of failing business and the additional regulatory pressures, Avtex eliminated 500 jobs and five of its eight rayon lines. In July, Avtex was fined $900,000 by a state court for continuing violations of its waste-water discharge permit. However, the company avoided an injunction ordering its closure and also avoided payment of the $2 million for civil penalties by promising to spend $9.3 million on cleanup (11). In late August 1989, “The state police seized documents from the Avtex office as part of a criminal investigation to determine whether the company deliberately discharged PCBs into the river” (2). The EPA filed a $9.1-million toxic wastewater cleanup order against Avtex and former plant owner FMC Corporation. Virginia state agencies also ordered Avtex to make $9.3 million in repairs to remedy numerous environmental and worker safety violations (2). In October, after several attempts by the state to close the plant for PCB pollution and for violation of a consent agreement, Avtex laid off 378 of the 744 remaining employees. Shortly thereafter, Avtex notified EPA that it could not comply with the June remediation order. Almost a year had passed since the Department of Defense bailout of November 10, 1988. The Attorney General of Virginia, knowing that the bailout had not only allowed NASA and the Air Force to build up their supplies of the carbonized rayon used in rocket nozzles but had also permitted these agencies to obtain the rights to produce this specialized rayon, decided that it was time to close Avtex once and for all. The VWCB revoked Avtex’s waste-water discharge permit. The EPA also proposed to fine Avtex $300,000 for PCB violations dating back to 1986. As a result, Avtex closed the Front Royal plant for the last time on November 10, 1989, a year to the day after the 1988 bailout (12). Passing the Buck The EPA dispatched an emergency response team to the plant, which was considered to be in a dangerous condition due to corrosion of an acid-treatment facility. Immediately afterwards, a state judge fined Avtex $6.15 million, the largest fine ever in a Virginia environmental pollution case. The State ordered Avtex not to remove property from the plant site, and the federal government filed a $40 million suit against the plant for the estimated cleanup costs. Although responsible for the cleanup costs, Avtex filed Chapter 11 bankruptcy in



February 1990, citing $3.3 million in debts that did not include the fines of $40 million from EPA and $6.15 million from Virginia (13). The EPA immediately ordered FMC Corporation to continue to operate the waste-water treatment facility at the site.10 When the EPA turned to the previous owner, FMC Corporation, to cover the costs of cleanup, FMC replied by suing the federal government for part of the costs, contending that the operations ordered by War Production Board were also responsible for the pollution of the site during World War II. “A federal court in Pennsylvania … ruled [in 1992] that the U.S. Department of Commerce [was] responsible for part of the Superfund cleanup costs at the site as the successor agency to the War Production Board” (14) (Attorney General News Release 3/3/97), but an appeals board overturned this ruling in 1994, saying that the case failed to illustrate that the government was an “owner, operator, and arranger” as stipulated by the Superfund legislation. The Superfund legislation also stipulates that the state in which the Superfund site resides must contribute 10% of the costs incurred in the cleanup of the site. At this site, the state of Virginia is also held responsible for all operations and maintenance costs of future remediation. As a result, “Virginia sued the federal government and FMC Corporation in February [1997] to recover its expenditures involving cleanup of the Avtex site. Virginia alleged that the federal government was as responsible for the pollution as the private operators of the site because it knew what was happening for years, did nothing to prevent it and even made an attempt in the Avtex case 1980s to keep the plant open” (15). The federal agencies named as defendants in the suit included the Department of Defense, NASA, and the Air Force. FMC Corporation and Thiokol Chemical Corporation11 were also named as defendants. This suit was headed by the new Virginia Attorney General, James Gilmore. In November 1997, the government agencies agreed to reimburse the state of Virginia $1.2 million. The EPA spent approximately $27 million on cleanup activities from 1989 to 1997 (16 ). In spite of these activities, threats to community health and safety still existed. In 1997 the ground water and soil in the area were contaminated with all of the toxins previously listed. The Shenandoah River was struggling with runoff from leaks of PCBs on the plant site. Furthermore, the DEQ reported that “public health may be threatened by ingesting or dermal contact with contaminated water or soil and inhaling dust from the site” (8). The DEQ specifically enumerated the following as community concerns: “contamination of the Shenandoah River, environmental risks, health risks, flow of information to the community, on-site landfill implications, potential for redevelopment, and usage to attract industry and jobs to the area” (8).

Figure 5. Use of a dredge to reclaim zinc hydroxide and convert it to zinc sulfate.

acid to produce a marketable product, zinc sulfate (17 ): Zn(OH)2 + H2SO4 → ZnSO4 + 2H2O Under a consent decree filed on July 9, 1999, FMC Corporation agreed to clean up the site at an estimated cost of $63 million and also to reimburse the EPA $9.1 million for past cleanup costs (18). Under the oversight of the EPA and the Virginia DEQ, FMC Corporation began remediation of the 440-acre site consistent with the redevelopment plans of the town of Front Royal and Warren County. To settle prior lawsuits brought by FMC, a number of federal agencies agreed to pay about one-third of the cleanup costs. This liability was associated with the government’s role (WPB) in the operation of the plant during World War II. On November 23, 1999, a Federal Bankruptcy Court judge in Reading, PA, cleared the way for the Front Royal/ Warren County Economic Development Authority (EDA) to acquire the 440-acre Superfund site for redevelopment. An initial payment was made to the bankruptcy trustee at the closing. Future payment will be made to the trustee, FMC Corporation, and the EPA as redevelopment activities continue. The EDA purchased the site in March 2000 and initiated redevelopment activities.12 Plans for the site include a 165acre office park with a 10-acre convention center. The park contains covenants with “green” and eco-industrial standards. The bankruptcy trustee, FMC, and the EPA will receive a portion of the profits from the sale of parcels in the park. In conjunction with the EPA, the National Soccer Association has selected 25 acres of the site to demonstrate the conversion of Superfund sites into soccer fields. The remaining 240-acre portion of the site between the Norfolk Southern

Cleanup and Redevelopment Activities FMC Corporation announced an agreement with the EPA and the Justice Department to clean up the Avtex Superfund site. An example of a cleanup activity is shown in Figure 5, where a barge is dredging sludge from a settling pond. The sludge containing zinc hydroxide is pumped from the pond, pressed to remove excess water, and then treated with sulfuric

Figure 6. Plan for redeveloped site.


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Railroad and the Shenandoah River will become a nature conservancy park with wildlife refuge, bird sanctuary, trails, boat landings, wetlands, and passive recreational opportunities (Fig. 6). An agreement guarantees that the EDA, Front Royal, and Warren County will not be held responsible for any past pollution that might be discovered on the site in the future. Employing parallel cleanup and redevelopment activities to convert a toxic waste site into useful land is a unique approach that provides a model for other Superfund sites. It improves the environment while maintaining or even improving the region’s economy. The final cleanup and redevelopment of the Avtex site required the cooperation of federal, state, and local governments as well as past, present, and future industries. It is a shame that it took so long to achieve while the local environment, workers’ health and safety, and the economy of the region suffered. However, the Avtex saga appears to be approaching a good ending. Conclusion Activities associated with national defense have often resulted in damage to the environment. In the production of both fissile materials and rayon, short-term requirements for national security took priority over long-term protection of the environment. While environmentalists often lose sight of the expediencies that caused this ordering of priorities, it also appears to be difficult for the defense establishment to learn from its experiences. In the late 1990s the Department of Energy (DOE) took steps to increase public awareness of the environmental impact of the production of fissile materials and nuclear weapons. Despite an increased awareness of environmental protection by the DOE and other members of the defense establishment, continued vigilance is necessary to avoid the mistakes of the past. The Avtex rayon saga shows that production of nonnuclear materials deemed necessary for national security can also have a major environmental impact and require massive cleanup efforts. Use of this Case Study with Classes This case study can be used with introductory chemistry, environmental science, environmental policy, and public policy classes. The following activities are suggested to enhance the pedagogical value of this case. Individual or group research papers and presentation may be assigned on topics such as National defense versus public safety Economic development versus environmental protection The effects of corporate mergers on the environment, worker safety, and local economies The transformation of a toxic Superfund site into an economically viable, environmentally compatible location The potential environmental effects of rayon production The rise and fall of rayon as a synthetic material A comparison of the synthetic polymers, rayon and nylon The chemistry involved in treating waste on the site (e.g., the conversion of zinc hydroxide to useful zinc sulfate); the MSDSs for the materials involved will be useful in this activity.

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Role-playing activities may be based on information from this paper and listed references (see the paper by Pharr [19]). Individuals or groups of students assume the roles of persons representing plant management, concerned citizens, the plant workers, state and federal agencies, the press, and environmental organizations. An excellent computer simulation of a case similar to the Avtex case is available from JCE Software (20, 21). Students may build a Web page that contains a time line of events associated with the Avtex saga. It could contain links to the chemical, environmental, political, economic, and legal issues associated with theses events. Students could work in teams, each member addressing a different aspect of the case. This case study may be used as an example of a comprehensive view of the scientific, environmental, economic, political, and legal issues involved with producing materials for civilian and military uses. Students may use this example to look at other cases such as The production of plutonium at Hanford, Washington The production of tetraethyl lead in Louisiana Dioxins as pollutants in paper manufacture Lead in paint Carbon dioxide emissions by coal-burning power plants

The following Web sites are good starting points for obtaining more detailed information on the Avtex case (all accessed March 2002). Comprehensive information: http://www.avtexfibers.com/ Virginia Department of Environmental Quality site on Avtex: http://www.deq.state.va.us/waste/pdf/superfund/ avtex.pdf Avtex Development Project: http://www.wceda.com/ Default.htm Front Royal Warren County Economic Development Authority: http://www.wceda.com/newpage5.htm History of the Avtex plant: http://ourworld.compuserve. com/homepages/rdaniels2/layout2.htm Rayon production and uses, Fibersource: http://www. fibersource.com/f-tutor/rayon.htm

The documents recording the litigation provide useful insights into all aspects of the case. A good example is “FMC Corporation v. United States Department of Commerce”, United States Court of Appeals for the Third Circuit, 1994 U.S. App. LEXIS 16514: 38 ERC (BNA) 1889. These documents are found on the LEXIS legal library/database accessible by law schools and legal firms. LEXIS provides both summaries and full-text documents of cases. Acknowledgments We would like to thank Elizabeth Blackmer for her helpful discussions and critical review. This work was supported by the Robert E. Lee Undergraduate Research Program and a Glenn grant from Washington and Lee University. Notes 1. From 1918 to 1938, the world output of rayon increased from 29 million pounds to 2,200 million pounds. (The Origins and Development of Courtlands between 1700 and 1986, no author given, p 14.)


Chemistry for Everyone 2. The owners retained the name American Viscose. 3. The WPB had power over plant expansion and conversion, production, purchasing, contracting, construction, and financing for facilities that produced goods judged essential to the war effort. 4. Cotton linters are the fuzz of short fibers that adhere to the cottonseed after ginning. 5. Most rayon is produced today by the viscose process (http:// www.fibersource.com/f-tutor/rayon.htm). 6. A leveraged buyout is one in which the purchaser of a company uses borrowed money for a substantial portion of the purchase price. 7. Although global production of manufactured fibers increased 115% from 1979 to 1999, the percentage of cellulosic fibers, the classification that includes rayon, decreased from 23% to 7% of the world’s production during this period: http://www.fibersource.com/ f-info/fiber%20production.htm. 8. Asia became the largest producer of manufactured fibers, increasing from 25% of the world’s total in 1979 to 58% in 1999. In this period the North American’s share of the total decreased from 37% to 19%: http://www.fibersource.com/f-info/fiber%20production.htm. 9. PCBs originate from oil used in electrical transformers found on many industrial sites. 10. FMC had retained ownership of the waste-water treatment plant after the sale of all other facilities to Avtex. 11. Thiokol had a contract for the production of chemicals at the site. 12. A time line and plans for conversion of the site can be found at http://www.wceda.com/newpage12.htm.

Literature Cited 1. Linking Legacies: Connecting the Cold War Nuclear Weapons Production Processes to Their Environmental Consequences; U.S. Department of Energy, Office of Environmental Management: Washington, DC, 1997. 2. Reisch, Marc S. Chem. Eng. News 1989, 76 (Sep 18), 11–14. 3. Delmonte, John. Technology of Carbon and Graphite Composites; Van Nostrand Reinhold: New York, 1981; pp 49–55, 399–400, 413–417.

4. Anonymous. A Half-Century of Trouble; Richmond Times Dispatch, Nov 20, 1988, p B-1. 5. Cohn, D’Vera; Pae, Peter. Avtex Case, Need for Jobs Outmuscles Fear of Hazards, The Washington Post, Nov 13, 1988, p A01. 6. Carlson, Peter. Rayon Men, The Washington Post Magazine, Feb 12, 1989, pp 22–29. 7. Pae, Peter Va. Textile Mill Cited for Water Pollution, The Washington Post, Aug 17, 1988, p B1. 8. Gladwell, Malcolm. Just What’s Behind the Avtex Closing? The Washington Post, Nov 21, 1988, p F01. 9. Anonymous. Avtex Told to Remove Chemical, Roanoke Times & World-News, Nov 12, 1989, p C1. 10. Virginia Department of Environmental Quality; Avtex Fibers; http://www.deq.state.va.us/waste/pdf/superfund/avtex.pdf (accessed Mar 2002). 11. Cohn, D’Vera. Avtex’s Legacy: Big Cleanup Bills, Questions, The Washington Post, Nov 19, 1989, p A1. 12. Anonymous. Chem. Eng. News 1989, 76 (Nov 20), 5–6. 13. Percival, R. V.; Miller, A. S.; Schroeder, C. H.; Leape, J. P. Environmental Regulation: Law, Science, and Policy; Little, Brown: Boston, 1992. 14. Virginia Attorney General News Release Mar 3, 1997. 15. Finn, Peter. Pollution Landmark Demolished in VA. The Washington Post, Nov 12, 1997, p B05. 16. EPA Region 3, Hazardous Site Cleanup Division. Avtex Fibers Inc.; http://www.epa.gov/reg3hwmd/super/VA/avtex/ (accessed Mar 2002). 17. Ellicott Case Studies: Valuable By-Product Recovered by Sediment Removal System Unit increases protection of Shenandoah River; http://www.dredge.com/casestudies/ flyash3.htm (accessed Feb 2002). 18. U.S. Department of Justice. U.S., FMC Settle Avtex Fibers Superfund Lawsuite in Virginia; http://www.usdoj.gov/opa/pr/ 1999/July/296enr.htm (accessed Feb 2002). 19. Pharr, D. J. Chem. Educ. 1993, 70, 294–295. 20. Whisnant, D. M.; McCormick, J. A. BCTC; in General Chemistry Collection [CD ROM]; JCE Software SP-16; http://jchemed. chem.wisc.edu/JCESoft/Programs/GCC/ (accessed Feb 2002). 21. Whisnant, D. M.; McCormick, J. A. J. Chem. Educ. 1992, 69, 42.


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