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"?1th -u Mt Panama all: lua?mdd" 5! :1 0'3 . 11 Pills 543?? .. an! nut: ?that tu?al Montgomery, Alabama 0 Friday Morning, Staff and Wire Report Federal grand juries in several, states are investigating allegations of anti-trust activity involving price fix-- ing. bid rigging and conspiracy to di- vide customers and territories among large waste disposal ?rms. at U.S. Justice Department spokesman said Thursday. .One ?rm involved in the investigations owns an Alabama tox- ic waste dump. the largest in the United States. . A spokesman for the toxic dump 'wmel' said the company was aware the investigations hut downplayed the campany?s rel-2 i? it. "We are aware 01? ?ve locn; grand jury investigations looking at the waste hauling industr said William 'Plunkett. a spokesman for ., Management Inc. OWnerSOfEmelle Du Waste "We do not believe we are the subject of those investi- gations; However. in Memphis. where -we have an operation. we understand the investigation is focused on a peri- od prior to our ownership there." The top national waste hauler. Waste Management Inc.. is head- quartered in Oak Brook. 11 Chi- cago suburb. it purchased its Memphis operation. Waste Manage- ment in 1984. Plunkett said. The parent ?rm also owns Ch""?fcal Was-1%" Management Inc. 2" near i-Imc- lb;- . hazardous waste site. OIECLLJ at Emellc' were unavailable for com- 1 "Lu. June 5, 1987 ment Thursday. A spokesman for the Justice De- partment said grand juries are oper- ating in Birmingham. as well as .Memphis. Tenn. Orlando. Fla, and Fort Lauderdale. Fla. Investigations also are being conducted in vania. New Jersey. Arizona. Ohio and California. The No. 2 waste hauler in the na- tion. Houston-based Browning-Ferris Industries. Inc.. which bids on con- tracts in Alabama. also is under investigation, authorities said. believe we have .3. tszn. -. have not." said Peter Block. a in"! spokesman Thursday. .. But the owner of a large Montgom- ery-area private waste hauler. tied to Waste Management through a 10- year joint venture agreement. said he is used to the Justice Department asking questions. . . . ?That's nothing new." said Dur- ward Jackson. owner of Waste Away Group Inc.. with corporate headquar- ters at 648-3 S. Perry St. "The Jus- tice Department's been in Alabama since 1973. They?ve been in my of?ce and talked to me. That's theirjob." .?rc?tson said ziis gem?; wen-arc 'h?t I age-,3 ?wwterms at? the numerator?. imam .1. ?agement provides venture capital in exchange for a gross business. . Since. entering the .agreement'in'" 1985. Jackson said his business has tripled, em oilicer stock. he said. 1 . Insurance costs. and land?ll the only mp Investigated percentage of the playing 23! workers. He'is? and owns all?.the' prob: lems have plagued the disposal in-' (luslry everywhere. Jackson said. and have forced 60 percent. 9? A?A'Jama's nt-Evnte haulers out n? business in the "lih . u- n. ge'l?ting .. :t?s only - to come - arms Paulina. OR Co.) (Cir. 0. 303.154) 1? we 6 :937 Jilin} I. P. C. 8 Eat. ?th By DAVID SARASOHN Associate Editor. The Oregonian EVEN IN A TIME when candidates may soon be holding slide shows of their x-rays. full disclosure can't get much fuller than it did in Seattle last week. At least. one hopes it can't. At a neighborhood meeting to discuss a proposed garbage incinerator. Shelley Stewart. toxics director for Greenpeace, introduced a new exhi- bit: the mayor?s gar- bage. Stewart had sl?- ed through two garbage cans and two plastic bags outside Mayor Charles Royer?s home. and then publicly pro duced the incriminat- ing evidence: recycl- able and compost- able yard waste. Unfortunately. the meeting itself was not SAHASOHN captured on film. but 1 immediately thought of it as the ?nish of a "Perry Mason" episode: "You say you believe in recycling. Mayor Royer? Perhaps you would like to explain this!" Stewart slams down a dented Budweiser can. the mayor recognizes it and turns pale. specta- tors faint. and reporters rush for the phones. According to Stewart, the only thing wrong with that scenario was that the mayor wasn't actually at the meeting. As she 'brought out each item that could have been recycled. "The crowd was crying out in delight." she explained Monday. "Besides the recyclable material. there were even stronger boos for some or the styroi'oam items." Mayor Royer. I?m going to have to ask you to come down to headquarters. I think you know what I?m talking about. A little matter of the remnants ot?a Big Mac. "Itth seems to me it illustrates a point." Stewart told the Seattle Times after her appearance as a garbage guerrilla. lot of people who don't source-separate their gar- bage don't realize how truly easy it is to souroeseparate and then recycle their gar- bage." it illustrates a point. all right. but not one that has much to do with source-separation. To get to the mayor's Hefty bags. Stewart had only to go one step further on a trail that already runs deep into politicians' private ves. The most prominent milestone was reached earlier this year. when Gary Hart found Miami Herald reporters staking out his house and racing into print with his guest list. Subsequently. the Cleveland Plain Dealer. responding to Ohio Gov. Richard Ce- leste?s denial that he had "Gary Hart-type problems" Hart has become the euphe- mism for the reported that he did. too. The New York Times being the newspa- per of record. then requested all the candi- dates to supply it with their medical records and their FBI ?les. With the 'l?imes' legend- ary delicacy. it omitted dental X-rays. And it has been only a little while since television viewers learned things about Ron. ald Reagan's colon that are normally a secret between it and the small intestine. So Stewart may have been lucky to get to the mayor's garbage cans ahead of someone with a press card. Especially in the Paci?c Northwest, with its well-known concern about the environment. a public figure should be prepared to stand by his garbage. He may now have to stand by it with a shotgun. The voters. one can claim. are entitled to know whether an Of?ceholder who claims ?aw political issue has funny smel that recycling is a public goal actual source-separates. or whether cans and ties mingle casually in his plastic bags. If has young children. recycling fans would interested in whether he uses cloth or posahle diapers. although probing that its might be beyond even Stewart's investig live instincts. It is not just a question of behavior: in it justification used for every other incursin into politicians? lives this year. it's a que- tion of character. Alter all. you are what you don?t eat. Royer's initial response was strong; immediate public comment involved a entirely different kind of waste materie Monday. after further consideration. press secretary offered other responses. Taking the offensive. Ann Fennessy pair ed out. "We don't even know if it's really It garbage." She then noted that the mayor he held a fund-raising event for 300 people his home that week. arguing. ?He and h- wife do recycle. but you can't control ever: thing." Fennessy also said that the mayor he received an overwhelming number of call and support on the privacy issue. which i one hopeful sign amid the eggshells and on: fee grounds. Stewart conceded. would cer tainly be willing to concede that his privac: was invaded. and for that apologize to th: mayor and his wife." But. she says. get the impression did he couldn?t get any further than the ember rassment factor." Despite the broader impli cations. Royer ?rmly refused to debate hi- garbage with her. Maybe not this time. But if present trend: continue. the time will come when a candi- date's garbage will not be hidden from pub- lic scrutiny. But when it starts holding its own press conferences. don't save me a seat upfront. 55417.? Fania-u? PAGE - . xii-7 Ecologi's ts See War-rungs In Sea Pollution Incidents By JOHN NOBLE wttrono Along the East Coast. where tides lave been running an ugly brown and garbage washes ashore. where some waters have become unsafe for swim- ning and lethal to a multitude of fish, he summer of 1987 should be viewed ,a a cautionary tale. environmental ex- erts and Government officials say. The unpleasant summer. which cost poll on thousands of vacations. was a emonstration of how delicate is the alance of the marine environment. prerts agree that the problems. the esult of conditions long established. all be repeated from time to time. And think that enough is being done bout them. "i don't think the future looks good." aid Virginia K. Tippie. director of es- tartne programs for the National ceanic and Atmospheric Administra- on. "We need to take action now to re- :rse the trend." - Biggest Danger ls Seafood Except for isolated danger spots. the :can is expected to remain safe for iman recreation in the near future. to most significant health danger will intinue to be from its food products. mm are increasingly showing signs contamination. rather than from Rimming. The reported number of ill- :ssu from swimming mainly gas- oenteritis does show a small rise it remains minor. in the view of pub- :heaitl'i experts. Appalled as people were at the sight scum on water and the thought of rimming in fecal beeteria. there were on some reasons to be encouraged. )vernmerit scientists said rivers nptying into the oceans are generally inner than they were a few years ago despite inctdents of raw sewage tcharges and garbage on beaches, 1: quality of some coastal waters has iproved. The deep Ocean. beyond the are vulnerable shore waters. re- ams clean and thrivmg. But as fish kills and brown tides of ac relentlessly call attention to the iespread choking of some waters :h nutrients that deprive animal life oxygen. marine experts uniformly aress concern over the posSibility of su?tcter limits are not imposed. in on What :5 put in the ocean. Gov- imenl officials and ecologists med. the "stressed" marine enun- ronment in heavily populated areas could deteriorate further. This could bring economic rum to the seafood in- dustry. a blight to shore resorts and widespread health hazards. The Challenges Ahead At a Congressional hearing last week on polhition along the New Jersey shore. particularly hard hit in recent weeks. Qiristopher J. Daggett. a re- gional administrator for the Environ- mental Protection Agency. said, "The events of the summer have made it clear that there are further diallenges aheadofustobe mettfwearetocon- tinue to protect our coastal waters." Even though Federal legislation in the 1960's and 1970': has had some suc- cess in restricting waste chimping and the discharge of raw sewage. scientists noted. organic chemicals. metals and disease-causing bacteria continue to 1 build up to dangerously high levels in coastal waters. "We're finding the ocean can't ab- sorb them all." said Donald F. Squires. director of the University of Connect- icut's Marine Scienm institute at New London. "We're going to have to Stop productng some of these neurons sub- atances." A recent Congressional study found that many of the nation's bays. eStw Contlnued on Page 42, Column 1 one If} W, ?2 NEW YORK TIMES. SUNDAY. SEPTEMBER f3. f98? Ecologists Observe Warning Signs In Summer?s Ocean Pollution Scares Continued From Page aries and other coastal waters are "in deep trouble"-from increasing waste disposal activities. In a report issued before this sum- mer's events. the Congressional ("fire of Technology Assessment said human illness from eating contaminated shell- fish or in contaminated waters was rismg. The maior rise has been in cases of gastroenteritis. such as food poisoning and stomach "flu.? both from eating seafood and swim- ming. Several outbreaks have been re- ported in recent yea rs in New York and New Jersey. Hepatitis A is frequently contracted from eating raw or under- cooked shellfish. and in Louisiana there has been a higher number of reports of cholera from eating undercooked shell- fish, especially crabs. The Congresswnal report also said . commercial harvests from about one- third of productive shellfish areas are now prohibited or restrICted because of contamination. Existing regulations. the report concluded. "will not be sufficient to maintain or improve the health" of coasml waters. An examination of New England's fisheries. conducted by Coast Alliance. an environmental group based tn Washington. found that ?hardly a Coastal town is safe from contamina- tion of its fish and shellfish.? Similar problems afflict New York and the Middle Atlantic States. other said. New Yorlt has at times had to sus- pend clammi?ng and fishing for striped bass because of chemical contamina- lion. ll The fundamental problem. according to all the experts interviewed. is that coastal communities have always looked upon the ocean as a waste re- ceptacle. counting on its immensity to dilute and dissipate the pollutants. The coastal waters? capaCity to handle wastes has been severely strained by population growth. About 70 percent of the nation's population lives on or near the coasts. Because population growth along the shore is likely to continue and reposito- ries for women land are already over- taxed symbolized by the vagabond garbage barge front Long Island that no one wanted people will have no al- iemative but to keep using coastal waters for waste disposal. The pres- sures are greatest along the East Coast from Massachusetts to the Carolinas and in some cases Florida. Problems are also becoming serious along the- Gulf Guam and parts of the Pacific Coast Government scientists who monitor ocean conditions said the most preva- lent manifestation of coastal degrada? tion seemed to be hypoxia. the deple- tion of dissolved oxygen in near-shore waters caused primarily by an over- load of waste nutrients. Hypoxia was especially vistble this summer. Fish that died from a lack of oxygen floated ashore. Lobsters in Long island Sound were found in their pots. Unusual weather conditions were di- rectly responsible for many of the fish kills. said Edward Carpenter. a marine scientist at the State University of New York at Stony Brook. A Peril of ?farmer Water July was especially hot along much of the coast. and warmer water is lea able to hold oxygen. To add to the prob? lem. there were few storms this sum- mer to churn coastal waters. mixing and aerating cooler bottom waters with the upper layers. In time. the decay of dead organisms falling to the bottom even depleted the oxygen there. ers such as worms. clams and crust!? . ceans die in place. Fish that do not die where they are try to eseape in shallow waters. where they often die from starvation and predation. One of the worst fish kill: this summer occurred in western Long island Sound. acknowledged that hot- summer stagnation was only the ing- ger for much of the widespread hypox- ia. A root cause was sewage and a heavy load of nutrients. like nitrogen and phosphates. that flow into enm- aries from munic1pal sewage trut- ment plants. industrial and urban drains and rain water leaching tural fertilizers from fields consumes nutrients that built up through the wmier. But later in the summer. rampant algal growth also consumes oxygen. especially when the algae die and sink to the buttom to decay. Dr. Carpenter said the organisms in much of this year's "brown tide" have been identified as Aureococcus anorex- eierens. a type of algae called golden- brown. He said the organisms have no apparent direct effect on human health. although research in this area is inadequate. Oxygen Pmblern Worsening Ms. Tippie cited Government statts? tics showing that the problem of low- waters on the ?35! Coast is "getting worse and worse." She said the study showed a 15-fold increase in hypoxic conditions and a significant de- cline in the commercial catch of fish and shellfish. Among the most critical areas are Long island Sound. the New York Bight off New Jersey, Chesa? peake Bay. Pamlloo Sound in North Carolina and Biscayne Bay at Miami. In the first cooperative effort to ad- dress the low-oxygen problem. officials of the states bordering Chesapeake Bay drafted an agreement this sum- mer that would attempt. by the year 2000. to reduce nutrients entering the system by to percent. Government scientists hope similar arrangements can be worked out for outer problem areas. Scientists said the mystermus deaths of scores of dolphins this summer off New Jersey and Virginia were appar- ently not related to any of the known pollution problems. Now it appears that the dolphins were afflicted with a pox virus that caused skin blisters. 'hld'l mpoired and became infected. A Punilng New Outbreak Just as the dolphin crisis seemed to have passed two weeks ago. the Na- tional Marine Fishenes SerVice re- WM outbreak of an dis- Relatively immobile bouom-dwell?lm in sdiools of menhaden from Del-true as far south as die mouth of the St. Johns River in Florida. Menha- den. caught mainly for fish meal and fish oil products. account for 40 percent at the gross annual fin fish catch in the United States. The concern is that the disease might affect future spawning and spread to outer species in the same waters. such as?otmder. weakfish and croalter. The cause of the outbreak is unknown. the flat'ieries service announced. ?but envi- rmn'iental factors pollution and water flow changes are possible causes or exacerbating factors." Federal legislation. notably the 18112:: Water Act and the Marine Pro- Decomposing sewage consume! dry. teem Research and Sancruaries Act. gen in the water. and an excessofnutri- has led to improvements. With an in- ents encourages the growth of algae lcrease tn muniCipaI sewage treatment and other micro-organisms. Normal 'piants and tighter regulation of ocean ramounts of micro-organisms. These lalgalgrowm the is good. for dumbing. New treatment plants have idaln are expected to help Troubled Waters: 0 Senate helped make generally cleaner the rivers that flow into the ocean. Scien- tists said. By the end of the year. the E.P.A. said. dumping of processed sew- age sludge by New York City and other municipalities have been moved from a site 12 miles offshore to one 106 miles out. Dismay Over Budget Cuts But enVironmental groups complain that budgets for more sewage treats menl plants have been cut by the Rea- gan Administration. They also charge that the E.P.A.. which has bad staff cuts. cannot effectively monitor coastal pollution problems. The agencytrack down the source a the dumping of garbage. including medical waStes. that caused the closing of 50 miles of New Jersey beaches in August Mr. Daggett or the E.P.A. told New Jersey last weelt that. such illegal dumping "may reqmre State or local controls similar to those federally m- stituted to control the generation. transportation and disposal of hazard ous wastes." Selentists of the National Oceanic and Atmospheric Administration are experimenting with satellite sensors and imagery to monitor water tem- peratures and the spread of abnormal . An Index of Oxygen Depletion ?9 .. if? .. The most prevalent 1.3; ?3 ?ao problem poaching East - Coast water is the lack 6th - si as greates mi.- 2233?? and an index ofz?dgo'f?i .21 New York Bight -20 dumpmg mus: Delawaie - ?0 Olygen daplgm; The ?1 Bay 0 dark barshoms'lm sludge input ihou;_ ggesaoeake -U - Bo sands of ionsotsplid's'a??; ?almme :60 year: the cieanbarinBiI- Ink: 3 Sound 0 cafes predictedamquhhi' - . no for the year militw Pamiico Sound a - depletion Df'dii' . . Charleston- 12? oxygen in watertis I . Harbor 0 a? --D as hypoxia1980 . and waste r? r? .3. ., ingthe dentin1 Deccan-Igy- - 33" posing wastesboonsuine4Q711; . oxygen. gr I - D2000 . ., trients encourage? . igpg'jj ea so . ?thatalso ?0 when theydiohand- - 1.7-, it.? 2. 20 decay ,2 in hea load "if; 0 Priority Hypoxic Areas 0 Potential Hypoxic Areas . 5e . - TN New Volt ?mills-?. U. IIT study changing ecalogicai conditions and advise when to close beaches. Toxic Chemicals Proliferate Anciher area of concern is the in- creasing presence of toxic chemicals in coastal waters. 3 problem that is espe- cially insidious because usually the . substances cannot be seen and their ef- fects are poorly understood and usu- a -term cumulativ Among the poreniia most dangerv ous of these subatances are lead. cad- mium. mercury. biphe- (PCB's). aromatic hy- drocarbons and petroleum hydrocar- bons. "There are so many new chemi- cals each year." Ms. Tippie said. "we can?t even get a handle on what's going it _Unlv in the last 20 veers have toxic sawmill wastes. been i: a ro em. ey a mos never iSinie- i ater. And they tend to be- come more concentrated in animals high on the food chain. particularly in the flesh and bones of fish and shellfish. Medical solentiSts have found that consumption of these toxic subatances can cause acute poisoning. an in- creased risk of cancer and problems in fetal development. Arid Contamination of clams and lobsters has cost North- east fishermen millions of dollars in lost busmess. quantify (until citizens bring a lawsuit and the court awards them damages), but these are nevertheless real costs and an attempt should be made to incorporate them into the tipping fee. Based on close analysis of landfills run by the City of New York, NERA's economists have come up with conserva? tive (thus probably low) estimates of the true costs of running a landfill. Their analysis is conservative in the sense that they did not calculate the opportunity costs of land out into the future after landfill closure, and they figured the cost of environmental damage as simply the cost of an insurance policy to insure against the damage. Despite these low estima of costs, the authors say a tipping fee that accurately reflects the actual costs of landfilling should be $35 per ton. They then present actual tipping fees being charged around the country: in New Jersey, they range from $16 to $32 per ton; in New York they range from $19 to $40 per ton. In Connecticut they range from $15 to $50 per ton. In Chicago: $13; Dallas: Detroit: $5.25 to Houston: Indianapolis: $11.75; Los Angeles: $10 to $12; Memphis: $5.50 to $7.90; Phoenix: $10 to $14; San Antonio: $7.35; San Diego: $8.00. Small wonder that landfilling is a popular technology?? it's cheap because the true costs of using a landfill aren't being paid _by the people using the landfill. The authors point out dangers Princeton, NJ 08543. Editor: Peter Montague, Assis mailed first class every ?cnday from Princeton, NJ. non?profits. $5 for students and senior citizens, $100 for associated with higher tipping fees: (3) rates should probably be raised over a several-year period to minimize the shock and let people adjust to the new realityof expensive dumping; proper pricing may make it appear that governments are making profits on dumping and this can cause political problems; increased rates may lead to increased illegal dumping, so increased law enforcement will be necessary as tipping fees rise; and, lastly, if tipping fees are regulated by boards of public utilities (or other public bodies) these bodies may prevent haulers frompassing on the increased tipping fees to their ,u customers, in which case the real source - of the problem (the haulers' customers) will not get the correct economic signals. This clearly-written report is available from National Economic Resea- Associates, 123 Main St., White Plains, NY 10601; phone (914) 681-7200; ask for I'Underpricing of Landfills," by Mark Berkman and Frederick Dunbar. LANDFILL RESEARCH PROGRAM Of interest to landfill fighters: "Briefing DocumentforScienceAdvisory Board Review of Land Disposal Research Program." Write Bob Steinberg, EPA, 26 West St. Clair St., Cincinnati, OH 45268;? phone (513) 5' ga"; ?h?i'foundation, p. o. aBox_ 3561. '?iR ikor'i?l nette Eubank. The News is SUBSCRIPTION ORDER FORK Name: Address: City: State and zip: Subscr tione 959 year foreindiuiduals-and- - i it: Research Foundation _lkttiNaniam-ialaa as] RTN T0 SENDEH ING eaox HARUE LA 70058? ~1aoe Coup Ms. Linda King CCHW L) 3828 Birchfield Harvey LA 70058 FIRST CLASS HAIL Fl HEALTH EFFECTS ATTRIBUTABLE T0 COAL AND NUCLEAR FUEL CYCLE ALTERNATIVES Draft R. L. Gotchy Manuscript Completed: September 1977 Date Published: September 1977 Division of Site Safety and Environmental Analysis Office of Nuclear Reactor Regulation U. 8. Nuclear Regulatory Commission Washington, D. C. 20555 --. .. . x. 3.5.: . Knoll ?wan-.lull-1.. . ?0.25} . ACKNOWLEDGMENTS The author wishes to thank the numerous members of the Nuciear Reguiatory Commission (NRC) Staff who provided support and assistance in preparing this report. In particuiar, the author wouid 1ike to thank Lawrence Chandier for his tireiess and invaluabie assistance. and Jacqueiine and Mark Doyie for their se1f1ess help in assembiing the data base used in preparing this report. ii a Fan?unnum- .- ABSTRACT 1' Estimates of mortality and morbidity-are presented based on present-day knowledge of health effects resulting from-current component designs and'operations of the foal cycles, and anticipated emission rates and occupational exposure for the various fuel cycle facilities.expected to go into operation in approximately the 1975-19852period. It was concluded that, although there-are large uncertainties in the estimates of potential health effects, the coal fuel cycle alternati has a greater health impact on man than the uranium fuel cycleG?'13-? ?Wig? ., ?an? warmer?FJr?t 4 . tin-if i . - - TABLE I0 II. OF CONTENTS INTRODUCTION RESULTS OF THE HEALTH EFFECT - ASSESSMENTS A. Health Effects of the Uranium Fuel Cycle B. Health Effects of the Coal Fuel Cycle C. Other Conslderations SUMMARY AND CONCLUSIONS APPENDIX A - Some Important Assumptions REFERE Affecting the Fuel Cycle Health Effects Evaluations NCES Although exact identity in treatment with respect to every aspect of environmental comparison of alternatives may not be required, this kind of companison goes to the heart of NRC's duty under NEPA,-where coal and nuclear power are shown to be the only two feasible alternatives. (Tennessee Valley Authority (Hartsville Nuclear Plant, Units 1A, 2A, 13, 28), ALAB-367, 5 NRC 92). As a result of the Hartsville decision, the NRC staff prepared testimony for ongoing hearings, and similar input for current environmental statements where such considerations were lacking. That testimony, which has now been presented in numerous public hearings,.is the basis for this draft NUREG report. Following receipt of coments from Federal and State agencies, industry, and concerned members of the public. and review of a forthcoming report by the National Research Council Committee (National Academy of Sciences) on Nuclear and Alternative Energy Systems, the NRC staff will prepare a final report, incorporating as many of the comments and new MAS data as appropriate. I. INTRODUCTION The National Environmental Policy Act of 1969 (NEPA) requires the Federal Government to use all practicable means, consistent with other essential considerations of national policy, to assure, among other things, that the Nation may: Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations. Assure for all Americans safe, healthful, and productive and pleasing surroundings. . Attain the widest range of beneficial uses of the environment without degradation, risk to health and safety, or other undesirable and unintended consequences. Farther, with respect to major Federal actions significantly affecting the quality of the human environment, Section 102(2)(c) of the NEPA calls for consideration of, among other things: The environmental impact of the proposed action. Alternatives to the proposed action. As a result of recent decisions by the Administration regarding the Nation?s energy policy, it is clear that the major alternative to nuclear-power for meeting the Nation's baseload electrical needs for the rest of this century is coal power. NRC environmental statements have discussed the impacts of the coal fuel cycle in terms of economics, and generically address those impacts in terms of land and water use. However, on January 25, 1977, an Atomic Safety and Licensing Appeal Board rendered a decision which stated: A disproportionately large part of the analyses comparing the coal and nuclear fuel cycles is focused on costs rather than environ- mental considerations. Nhile the effect on human and animal life of the emissions from the proposed nuclear plant are discussed in detail, there is no corresponding discussion with respect to the postulated coal plant. No mention is made of the environmental effects of the coal fuel e. .- II. RESULTS OF THE HEALTH EFFECTS ASSESSMENTS In making these assessments, the entire fuel cycle rather than just the-power-generation phase was considered in order to compare the total impacts of each cycle. For coal, the cycle consists of mining, processing, fuel transportation, power generation, and waste disposal. The nuclear fuel cycle includes mining, milling, uranium enrichment, fuel preparation, fuel transportation, power generation, irradiated fuel transportation and reprocessing*, and waste disposal. In preparing this assessment it has been recognized that there are large uncertainties due to the lack of an adequate data base in certain areas of each fuel cycle alternative. The overall uncertainty in the nuclear fuel cycle is probably about an order of magnitude, while there may be as much as two orders of magnitude uncertainty in the assessments of the coal fuel cycle based on the range of published values. The much greater uncertainty associated with the coal fuel cycle results from the relatively sparse and equivocal data regarding cause effect relationships for most of the principal pollutants in the coal fuel cycle, and the effect of Federal laws on future performance of coal fired power plants, mine safety, and culm bank stabilization. Health effects, as it is used here, is intended to mean excess** mortality, morbidity (disease and illness) and injury among occupational workers and the general public. The most recent and detailed assessments of health effects of the coal fuel cycle have been prepared by the Brookhaven (Refs. 1,2,3,4) and Argonne (Refs. 5,6) National Laboratories. The most complete and recent assessment of the radiological health effects of the uranium fuel cycle for normal Operations was prepared for the ?Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Hater Cooled Reactors (GESMO 1) (Ref. Although the Administrations's announced energy policy Opposes the imple- mentation of commercial fuel reprocessing technology at this time, Table S-3 (10 CFR Part 51) assumes reprocessing. This tends to upper- bound the radiological impacts since the recycle of uranium after repro- cessing results in more radiological effects than no recycle of uranium from irradiated fuel. "Excess? is used here to mean effects occuring at a higher than normal rate. In the case of death it is used synonymously with premature mortality. with the Commission's announced intention to reexamine the rule from time to time to accomodate new information, (39 F.R. 14188, April 22, 1974, and 42 F.R. 13803, March 14, 1977), staff studies are underway to determine what areas, in addition to waste management and reprocessing, may require updating in Table S-3 (Notice of Proposed Rulemaking, Docket No. RM 50-3, Environmental Effects of the Uranium Fuel Cycle, 41, F.R. 45849, October 18, 1976). However, in accordance with l0 CFR Part the current impact of the uranium fuel cycie (excluding reactors and mines) is defined by the March l4, 1977 revision of Table 5-3, l0 CFR Part Using the Table 5-3 effluents and the models develOped for GESMO I, it was possible to estimate the impact of the uranium fuel cycle on the general public for routine operations. These values are shown in Tables and 2, and some critical assumptions related to estimates are shown in Appendix A. Since Table 5-3 excludes radon releases from uranium mines, the health effects of such releases on the general public are not included in Tables and 2. The effects of such releases would result in some small increases in the total risks of mortality and morbidity as discussed below under ?Other Considerations." In addition, Table 5?3 does not generically address releases for light water cooled power reactors. The estimated total body population dose commitnents for both occupational workers and the general public were taken from GESMO I (U recycle only option)*. In addition, the occupational dose commitnents to workers in uranium mines, mills, uranium hexaflouride plants, uranium fuel plants and uranium enrichment plants were taken from GESMO 1, since they are not considered in Table 5-3. However, these dose commitments are comparable to those which would result from the radiological releases in which provides background support for Table 5?3. The dose commitments to the public and occupational workers in the March l977 Table 5-3 were used for estimating health effects from the repro- cessing and waste management aspects of the uranium fuel cycle. The risk estimators used to estimate health effects from radiation dose commit? ments were taken from GESMO I and (Ref. 8). The impact of accidents in fuel cycle facilities (Ref. 9) and reactors (Ref. 8) generally does not markedly increase the impact of normal operations for the uranium fuel cycle, but has been included in this assessment for completeness. No comparable analysis of health effects resulting from accidents in coal-fired plants is available at this time. Estimates of death, disease and injury from non-radiological causes for the uranium fuel cycle are from the Brookhaven (Refs. 1,2,3) evaluations, with the exception of transportation accident related deaths and injuries, which were taken from Table 5-4, 10 CFR Part 5l. The results of these assessments are shown in Tables 1 and 2. It should be noted that there are two lines under the nuclear fuel cycle: the first assumes all of the electricity used within the uranium fuel cycle is generated by nuclear power all nuclear economy); the second line assumes, as shown in Table 5-3, *See footnote on page 1. (10 CFR Part Sl), that l00% of the electricity used within the nuclear fuel cycle comes from coal power. This is equivalent to a 45 Mwe coal- fired plant, or 4.5% of the power produced. A. Health Effects of The Uranium Fuel Cycle Currently the NRC estimates that the excess deaths per 0.8 gigawatt?year electric (GNy(e)) per l,000 power plant operating at 80% of capacity for one year) will be about 0.47 for an all nuclear economy. This is probably somewhat high due to the conservatism* required in evaluations of generic plants and sites. However, it is not greatly different from estimates by others such as Comar and Sagan (Ref. 10) (0.ll to 1.0), Hamilton (Ref. l) (0.7 to and Rose et al (Ref. ll) (0.50). The uncertainty in the estimate is about an order of magnitude.** If, as shown in Table 5-3, 100% of the electrical power used by the uranium fuel cycle comes from coal-fired power plants, the NRC would estimate there would be about 1.1 to 5.4 excess deaths per 0.8 GNy(e). Of this total, about 0.63 to 4.9 excess deaths per 0.8 GHy(e) would be attributable to coal power. The uncertainty in the estimate is about one order of magnitude. The total number of injuries and diseases which might occur among workers and the entire U.S. population as a result of nonmal Operations and acci- dents in the uranium fuel cycle was estimated to be about l4 per 0.8 GHy(e) for an all nuclear economy. Injuries among uranium miners from accidents such as falls, cave-ins and explosions account for l0 of the 14 cases (see Table 2). If 100% of the electrical power used by the uranium fuel cycle comes from coal-fired power plants, the NRC would estimate there would be about 17-24 injuries and diseases per 0.8 GNy(e). Of this total, about 3 to 10 excess effects per 0.8 GNy(e) would be attributable to coal power (See Table 2a). The uncertainty in the estimate is also about one order of magnitude. Although anticipated effects associated with normal releases of radioactive effluents from the nuclear fuel cycle are limited to potential cancers and leukemias, for the higher doses associated with serious nuclear accidents there is some small risk of various non-fatal somatic effects (see footnote c, Table 2). At this time only light water cooled power reactors (Ref. 8) have been thoroughly evaluated. However, it should Conservative is used here to mean that assumptions regarding atmospheric dispersion, deposition of particulates, bioaccumulation, and so forth generally result in estimates of impact that are typically "upper bound? estimates, and in most cases, the estimates would be lower for real plants. "Order of magnitude" uncertainty means the estimate could be as much as ten times higher or ten times lower. Health effects of a non-reproductive nature non-genetic). .. be noted that power reactors probably account for most of the potential health effects associated with nuclear accidents in the uranium fuel cycle. This results from the fact that they represent 80 percent of all the fuel cycle facilities expected to be Operating for the balance of this century (Ref. 7) and the majority of occupationally exposed individuals. In addition, although the probability of serious accidents is extremely small, if one were to occur, the health effects would be larger than for any other type of fuel cycle facility. Serious nuclear accidents in power reactors might also contri- bute about 0.04 excess deaths per 0.8 GHy(el. There is some controversy over the probabilities of occurrence of serious accidents, such as discussed in HASH-1400 (Ref. 8). However, even if the risks were, for example, twenty times greater than estimated in HASH-1400, the excess mortality for the uranium fuel cycle would only increase from 0.47 to 0.87 per 0.8 GHy(e). Transportation related accidents are estimated to contribute about 0.01 excess deaths per 0.8 (see Table la, footnote Early and latent non-fatal somatic effects which might be expected after high radiation dose effects include a variety of effects (see footnote c, Table I 2). It is possible that non-fatal somatic effects could be an order of magnitude greater than excess deaths resulting from accidents (Ref. 8), thus, the total number per 0.8 GHy(e) would be about 0.4. This accounts for about one-third of the morbidity shown for the general public and an all nuclear economy in Table 2. The number of non-fatal thyroid cancers (5-10: mortality rate) and benign thyroid nodules would be about 0.6 per 0.8 GRy(e) from routine releases to the public and occupational exposures (primarily external irradiation). while other non-fatal cancers would be less than or equal in number to fatal cancers (about 0.2 per 0.8 GHyleI) (see footnote c, Table 2 and footnotes and Table 2a). It is believed (Refs. 6,l2l that genetically related diseases* and abnor- malities in the descendants of workers and the general public from both normal operations and accidents would be perhaps twice the number of excess deaths due to cancer from total body irradiation; this could add another 0.3 health effects per 0.8 GHy(e) among workers and 0.l-0.2 health effects per 0.8 GHy(e) among the general public (see footnote c, Table 2). In assessing the impact of coal power used in the uranium fuel cycle, Table 5-3 was the basis for the assumption that l00$ of the electricity used in the uranium fuel cycle, primarily for uranium enrichment and reactor *Includes diseases such as cystic fibrosis, hemophelia, certain anemias, and congenital abnormalities such as mental retardation, short-limbed dwarfism and extra digits. (See footnote c, Table 2) operation, came from coal fired plants. Adding 4.5% of the health effects from.the coal fuel cycle per 0.8GHy(el significantly increases the health effects for the uranium fuel cycle per 0.8 GRy(e), as shown on the second lines of Tables and 2. 1 B. Health Effects of The Coal Fuel Cycle Current estimates of mortality and morbidity resulting from the coal fuel cycle are quite uncertain; this.is the principal reason for the wide range of values reported in the literature. These uncertainties, as discussed in more detail below, result from the limited number of epidemiological studies and differences in interpretation of the results of such studies. There is additional'uncertainty regarding the effects of new Federal laws on coal cycle facilities in the next decade. Current estimates of excess deaths for the entire coal cycle range from 15 to 120 per 0.8 GRy(el, while disease and injury estimates range from 57 to 210 per 0.8 GHy(e). In the case of occupational effects,1there is considerable uncertainty because of anticipated reductions in health effects resulting from the implementation of the Federal Coal Mine Health and Safety Act of 1969 (PL 91-173). The provisions of this?act should result in significant improvement of the underground work environment, particularly regarding coal dust. Coal dust is both a cause of underground explosions and fires, and a cause of coal workers pneumocohiosis (CHP), commonly called black lung disease, and subsequent progressive massive fibrosis In addition, more coal in the years ahead is expected to be produced by strip mining which results in lower mortality rates (Ref. As a result, the frequencies of both types of events is anticipated to decline in the years ahead, on a per GHy(e) basis. 0n the other hand, statistics show new coal miners experience higher mortality and injury rates than experi- enced miners (Ref. 5). As a result bf expected increases in coal production, an influx of inexperienced miners will tend to increase the mortality and injury rates for miners as a group. In the case of the general public*, there is also considerable uncertainty in the estimation of health effects. For example, although there are estimates of health effects related to burning culm banks (waste banks from coal screening), recent mine Operators have greatly reduced such fires, and future processing activities are expected to avoid fires as a result of new methods of stabilizing such banks to prevent slides. (Ref. 13). Current estimates of excess deaths in the public from sul- fates from such fires range from 1 to l0 per 0.8 GHy(e) (see footnote 9, In the case Of coal plant effluents, considerations of health effects was limited to the population within 80 km of such plants. a w. . -. q-mu . .. Tab1e 1). Power generation_ is estimated to resu1t in 3 to 100 excess deaths per 0.8 GHy(e) (see footnote 9, Tab1e 1), whi1e excess; morbidity ranges from about 10-100 per 0. 8 8Hy(e) (see footnote 9, Tab1e 2). - The uncertainties are even greater in the power generation phase of the coa1 cycie, where estimates of hea1th effects range over severa1 orders of magnitude. (Ref. 10-) This is 1arge1y due to the 1ack of a. '.re1iab1e data base for predicting hea1th effects from the various po11utants emitted from coa1 p1ants, and the effect of the EPA New Source- Performance Standards for coa1_p1ants regarding particu1ate and su1fur emissions inigfuture years on a 1ong-term basis. There is some uncertainty as to whether these stand- ards can be met in 1arge coa1- fired power_ p1ants over the 1ife of the p1ant. The major po11utants emitted inc1ude: I1 . 1. Particulates: Contain 1arge amounts of toxic trace meta1s in respir- ab1e partic1e size (Ref. 14) such as arsenic, antimony, cadmium, 1ead, se1enium, manganese, and tha11ium, (Ref. 5) significant quantities of bery1ium, chromium, nicke1, titanium, zinc, mo1ybdenum,l and coba1t 15), and traces of radium-226, 228 and thorium-228, F32. (Ref. ?rl 2. Hydrocarbons: Inc1udes very potent carcinogens (cancer causing substances) such as benzo(a)pyrene. .3. Su1fur oxides. 4. Nitrogen oxides n. 5. Other gases: Inc1u des ozone ,carbon monoxide, carbon dioXide, mercury vapor, and radon-222. 0f the preceeding 1ist of p011utants, there are no we11 estab1?ished epide- mio1ogic cause-effect re1ationships which can be used to accurate1y estimate tota1 hea1th effects either from acute exposures during air po11ution episodes or from chronic 1ong-term exposures. A1though definitive cause-effect re1ationships are 1acking, tentative cause-effect re1ationships for su1fur emissions have been -used by numerous groups to estimate hea1th effects from su1fur emissions from. coal p1ants. They are described by the Nationa1 Academy of Sciences in a recent report to the U. S. Senate. (Ref. 17) The most wide1y quoted studiesiare those by Lave and Seskin (Ref. 18). Hinke1stein et a1 (Ref. 19), and an unpub- 1.ished study by EPA which was used in the study for the U. S. Senate (1975). (Ref In general, the effects range from excess deaths from cardiovascular failure and increases in asthma attacks during severe air pollution to excess respiratory disease from long-term chronic exposures. Most of the acute deaths are among_the elderly and the severely ill, while morbidity from long-term exposure also includes children. Although widely accepted causeseffect relation_hips were not derived from acute air pollution episodes in London (195 (Ref. 20), Donora, (1948). (Ref. 21), and New York these studies definitely support the conclusions regarding excess death and disease associated with emisSions from.combustion of coal. There are no estimates of possible long-term carcinogenic effects by sulfur oxides or associated pollutants. In addition, the recently com- pleted (1976)* large scale EPA Community Health and Environmental Surveil- lance System (CHESS) study has failed.to provide any new or definitive cause-effect relationships for any of the pollutants from coal-fired plants which can be used to Provide better estimates of health effects than are currently available (see-for-example Ref. 23). - Assuming that new coal-fired plants i the 1980's can meet EPA New Source Performance Standards (which could reguire on the order of 99% particulate removal, and 90% sulfur removal for high sulfur coal), and other Federal laws regarding mine safety and culm stabilization, the number of deaths should be reduced. Thus, curnent estimates of 15 to 120 per 0.8 GHy(e), due largely to sulfates from'combustion coal may be reduced by about half to.8 to 60 per 0.8 GNy(e). . Recently, Argonne National Laboratorm has developed a predictive model for total deaths from emission of benzo(alpyrene, which indicates about 1 to 4 deaths per 0.8 G?y(e) depending on use of conventional combustion or fluidized bed Such effects, while greater than the expected deaths from the entire uranium fuel cycle (all nuclear economy), do not significantly change the total impact of the coal fuel cycle and were not included in the effects listed in Table l. Probably the most reliable estimates of deaths associated with the coal fuel cycle are those associated with'transporation accidents. Since a Hue coal-fired-plant consumes about 3 million tons of coal per year, 3?This 522 million study attempted to correlate air pollution data collected from six U.S. cities with a variety of health problems. there are-literally thousands of carloads of coal being transported by rail from mines to plants. It has been estimated that about.one out of every 10 trains in the U.S. is a coal train going to a coal-fired power plant. (Ref. 24) These trains are estimated to travel an average distance of about 300 miles from the mines to the plants. (Ref. 13) As a result, there are about 1.2 deaths per 0.8 GHyieIamong workers and the general public. Further, since most of these deaths occur at railroad crossings, the numbers can be expected to increase as more automobiles are operated?and driven greater distances, and as rail transportation distances increase when hauling low sulfur western coals to eastern markets. 1 Sickness among coal miners and the general public accounts for most of the non-fatal occurrences in the coal fuel cycle, with the remainder due to injuries.am0ng coal miners. As a result of implementation of Federal laws, it is-probable that future.rates among underground miners will be substantially reduced. It is not unreasonable to assume that the current estimates of about 57 to 2l0 cases of sickness and injury among workers and the general public could be reduced in the years ahead,.since occupa- tional sickness and injury currently account for about halfipf the total non-fatal health effects. I. The Brookhaven estimates, which form the basis of this testimony, show a range of uncertainty of about one order of magnitude. Theyuare well within .the range of values reported in the literature which range over about two orders of magnitude for the coal fuel cycle. c. Other Considerations 1 .I Although the.Reactor Safety Study (Ref. 8) has helped to provide a per- spective of the risk of mortality or morbidity from potential power reactor accidents (the current experience for serious_accidents is zero), there is the additional problem associated with individual perception of risk. Thus, while the Reactor Safety Study concluded that PAll non-nuclear acci- dents examined in this study, including fires, explosions, toxic chemical releases, dam failures, airplane crashes, earthquakes, hurricanes and tornadoes, are much more likely to occur and can have consequences compar- able to, or larger than, those of nuclear accidents," thereIwill continue to be uncertainty associated with such evaluations. Furthermore, there may be a problem of public acceptance of potential accidents, since the consequences can be severe. In fact, it appears that some people (Ref. 25) more readily accept,.for example, having 55,000 people actually killed each year in violent highway accidents, one or two at-a time, than would consider acceptable the unlikely occurrence of perhaps several thousand possible deaths from a single catastrOphic accident during their lifetime. I II I -10 4. cums-ur- As noted in footnote 5 to the March 1977 revision of Table 8-3 (10 CFR Part 51), the GESMO I radon-222 release increases from 74. 5 Ci to about 4,800 Ci when releases from mines are included. This increase would result in a small increase in the total number of excess deaths shown in Table 1, although the moratality per 0.8 GHy(e) for the general public would increase by about 30%. Hith regard to the coal fuel cycle, it is a well established fact that the'use of coal results in numerous other costs to society which have not yet been adequately-quantified. These include: 1. The short and long-term impacts of sulfur and nitrogen oxides on biota and materials. Acid rain, for example, is known to be severely damaging to terrestrial and aquatic habitats. Reference 5 provides a detailed discussion of these and other effects of sulfur and nitrogen oxide emissions. However, as more coal plants come on line, these effects can be expected to expand to surrounding areas. 2. Damage of materials, such as paints, building surfaces, statuary, and metals, from sulfur oxides, ozone and nitrogen oxide emissions. A 1976 review of such effects indicates that the costs could range into billions of dollars per year in the U.S. alone. (Ref. 26) 3. Contamination of soil and vegetation to toxic levels by such mechanisms as deposition and bioaccumulation of trace elements present in gaseous emissions. 4. Destruction of entire ecosystems_in streams and rivers by acid mine drainage, and the potential for public health effects from use of such water for domestic o? agricultural purposes. 5. In addition to the occurrence of excess mortalities, injuries, and morbidities, the costs to societ? in terms of medical costs, lost productivity, and other social losses represent a significant consid- eration which has not been compl tely evaluated at this time. Some recent studies have attempted to deal with these extremely complex issues, (Refs. 27,28) and concluded social costs from one coal fired plant may currently be about $50 'million per year, net considering the rest of the costs for the coal fuel cycle. - .- .. .. . 6. 7. The possibility of the so-called "Greenhouse Effect:" this phenomenon is expected by some (Ref. 29) to result sometime early in the next century at the present and future anticipated productiod rates of carbon dioxide from the combustion of fossil fuels. Since each 1000 coa]_plant produces about 7.5 to 10.5 million tons of carbon dioxide per year (Ref.'l) it is believed these emissions from hundreds of fossil fuel fired power plants may result in greaterireleases of carbon dioxide than the atmosphere and oceans.can cycle? As a result, the carbon dioxide concentrations would be expected to increase in the atmosphere. Since carbon dioxide strongly absorbs infrared, it is postulated that the mean atmospheric temperature will rise several degrees.- This may cause all or part of the polar ice caps to melt resulting in inundation of many inhabited areas of the world. At the same time drought would be expected to prevail in many of the agricul- tural areas of the temperate zones resulting in huge crOp losses. It is possible that the particulates emitted by fossil plants will countera act some of the Greenhouse Effect by reducing the amount of sunlight reaching the surface of the earth. . 4 However, another effect from carbon dioxide released byfcoal combustion occurs-since coal has essentially no carbon-l4. The stable carbon in effect dilutes the carbon-l4 in the biosphere, resulting in a redUction in the radiological impact of both naturally occuring and man-made carbon-l4. . 1 An additional consideration which has not been evaluated for the coal cycle is the.radiological impact of mining and burning coal. Of interest is the.release of radon-222 from the decay of radium-226 in coal. Not only is the radon released during mining and_combustion, but it will continue to emanate from flyash_for millions of years after the coal has been burned. Hhile Pohl (Ref. 30) has shown that this is not a problem with some eastern coal (generally of high sulfur content but with 1-3 uranium content), the average uranium and radium content of some reserves of low sulfur western coal is about so?times higher than most eastern coal (Refs. 31,32); Combustion of the coal and dis- posal of the remaining ash leads to approximately the same=health effects calculated by Pohl from radon-222 emissions as uranium mill tailings' piles per GHy(e). . These releases would account less than 0901 excess deaths per 0.8 GHy(e) from fuel cycle activities during the rest of this century. As a result, such releases do not significantly affect the conclusions reached with regard to a comparison of the two alternative fuel cycles. -12- . i In addition, some believe (Ref. that when the physical and bio- logical properties of the radium released from conventional coal powered plants burning coal (with 1-2 uranium-238 and Th-232) are considered, such plants discharge relatively greater quantities of radioactive materials into the atmosphere than nuclear powered plants- of comparable size. EPA has estimated radiation doses from coal and nuclear powered plants of early designs and reached similar con- clusions (Ref. 16). Even if the ealth effects from radioactivity released by the coal fuel cycle are greater than the health effects from radioactivity released in the nuclear fuel cycle, the total health effects from coal would not change significantly since these effects would be only a small percentage of the total health effects from- the coal cycle. SUMMARY AND CONCLUSIONS For the reasons discussed above, it is extremely difficult to provide pre- cise quantitative values for excess mortality and morbidity, particularly for the coal fuel cycle. Nevertheless, estimates of mortality and morbidity have been prepared based on present-day knowledge of health effects, and present day plant design and anticipated emission rates, occupational experience and other data.- These are summarized in Tables and 2, with some important assumptions inherent in the calculations of health effects listed in Appendix A. Hhile future technological improvements in both fuel cycles may result in significant reductions in health effects, based on current estimates for present day technology, it must be concluded that the nuclear fuel cycle is considerably less harmful tO-man thanithe coal fuel cycle. (Refs. l,2,3, 4,5,10,11,27,28,33,34,35,36) As shown in Tables 1 and 2, the coal fuel cycle alternative may be more harmful to'man by factors of 4 to 260 depending on the effect being considered, for a all nuclear economy, or factors of 3 to 22 with the assumption that a of the electricity used by the uranium fuel cycle comes from coal powered plants. It should be-noted.that although there are large uncertainties in the estimates of most of the potential health effects of the coal cycle, the impact of transportation of coal is based on firm statistics; this impact alone is greater than the conservative.estimates of health effects for the entire uranium fuel cycle (alP nuclear economy), and can reasonably be expected to worsen as more coal is shipped over greater distances. In the case where coal generated electricity is used in the nuClear fuel cycle, primarily for uranium enrichment and auxiliary reactor systems, the impact of the coal power accounts for essentially all of the impact of the uranium fuel cycle. -13- However, lest the results of this analysis be misunderstood, it should be emphasized that the increased risk of health effects for either fuel cycle represents a very small incremental risk to the average individual in the public. For example, Comar and Sagan (Ref. 10) have shown that such increases in risk of health effects represent minute increases in the normal expectation of mortality from other causes. A more comprehensive assessment of these two alternatives and others is anticipated from the National Research Council Committeelon Nuclear and Alternative Energy Systems in 1977 (Ref. 37). This studylmay- assist substantially in reducing much of the uncertainty in the analysis presentEd. -14- APPENDIX A Some Important Assumptions Affecting the Fuel Cycle Health Effects Evaluations: l. .The Uranium Fuel Cycle (RefThe Coal Fuel Cycle (Refs. 1,2,3) For mine and mill emissions it was assumed there was a population density from 7. 5 persons/sq.mi. in the west, to 160 persons/sq.mi. in the east, all uniformly distributed. For all other facilities, assumed 160 persons/sq.mi. density.* Used ?box" atmospheric dispersion model with vertical dispersion limited to 1,000 m, 2 m/sec windspeed, and cm/sec deposition velocity for particulates. Calculated the dose commitment from one year of operation for each type of fuel cycle facility. This dose commitment repreSents the sum of the 50 year dose commitments from the year of operation and each of the subsequent 39 years a 40 year environmental dose commitment). The total impact of the fuel cycle to the U. 3. population for the years 1975- 2000 was calculated using the needs for all types of facilities in order to meet current projections 'of power plants. Radioactive materials were not considered to be removed from food chains except by radioactive decay. Only in the case of carbon-l4 was an environmental sink assumed to be acting upon biological availability. and carbon-l4 not oved from the plume in the U.S. was assumed to mix uniformly in the world's atmosphere. Tritium is assumed to be mixed uniformly in the world's circulating water volume after depletion of the plume on its first pass over the U.S. Resuspension of deposited particulates was considered. Bioaccumulation of radioactivity in food chains was considered (generally upper bound estimates). Assumed an 80% capacity factor. Since the major impact of the coal fuel cycle results from power plant emissions, only those critical assumptions will be discussed: It should be noted that most of the calculated health effects would occur outside the 80 km radius of the plant. The mortality rate for the U. S. population is about 2, 000, 000 per 4%ear from all causes. - win-u..- APPENDIX A (continued) 1 :i Used actual population distributions within 80 kmiof'several nuclear plant sites: the average population was 3;8 million people.* i USed actual meteorology data from the same plants to calculate inhalation exposures to sulfates out to 80 km. - Assumed a-l,000 foot stack?for emissions. 1 Assumed use of 3% sulfur coal with 12% ash and per lb (eastern coal) for an upper bound.estimatenof health effects; assumed 0.4% sulfur coal with 3% ash and 12 thousand BTU per lb (eastern coal) for a lower bound estimate (approximately.the same sulfur emission as would result from use of high sulfur coal with flue gas desulfurization). Assumed 99% particulate removal from plant emissi?ns. Assumed a 10% per hour oxidation rate for conversion of sulfur oxides to sulfates. The dose-response relationships of Lave and Seskin (Ref. 18), Hinklestein gt 31 (Ref. 19) and others(as discussed in Refs. 1,2,3) were used.to calculate excess mortality and morbidity; adjustments were made for fractions of sulfates in the total suspended par- ticulates. . 1 Resuspension of deposited particulates was not di}ectly considered, _although deposition was. ?Assumed a 75% capacity factor. 'r I i _Experiences-about 36,000 per year mortality rate from all causes. Additional health effects from coal combustion are expected to occur outside this area, but have not yet been estimated. 3 '16" 1. -. . .- nun?4n? Table l. Current Energy Scarce Excess Mortality Summary per Year per 0.8 Guyie) Occupational General Public Totals Accident Disease Accident Disease Nuclear Fuel Cycle in) (cl (all nuclear) 0.22 0.l4 0.05 . 0.06 0.47 (with 100% of elec- (a.dl ib,el igl tricity used in the 0.24-0.25 0.14-0.46 0.l0 0.64-4.6 - l.l-5.4 fuel cycle produced by coal power (U.S. population for nuclear effects; regional population for coal effects) Coal Fuel Cycle id) if) (9) 0_3 . . 1,2 13.110 15?l20 Ratio of Coal to Nuclear: -32-260 (all nuclear) l4?22 (with coal power) Primarily fatal non?radiological accidents such as falls. explosions. etc. Primarily fatal radiogenic cancers and leukemias from normal operations at mines. mills. power plants and reprocessing plants. . Primarily fatal transportation accidents (Table 5-4, l0 CFR 51) and serious nuclear accidents. Primarily fatal mining accidents such as cave-ins. fires. explosions, etc. Primarily coal workers pneumoconiosis (CHP) and related respiratory diseases leading to reSpiratory failure.. Primarily members of the general public killed at rail crossings by coal trains. Primarily respiratory failure among the sick and elderly from combustion products from power plants, but includes deaths from waste coal bank fires. l00% of all electricity consumed by the nuclear fuel cycle produced by coal power; amounts to 45 Hue per 0.8 Guyie). - 1.8 Table la [Breakdown of Table l) NUCLEAR EYCESS MORTALITY per 0.0 GHyiel FUEL CYCLE OCCUPATIONAL GENERAL PUBLIC TOTAL COMPONENT - ACCIDENT OISEASE ACCIDENT OISEASE a [Baccal) (does, ?55 RESOURCE RECOYERY 0.2 0.030 .0 (Mining. Drilling, etc.) PROCESSING H) 0.042 0.002 RONER GENERATION 0.01 0.061 . - 0.04 0.011 STORAGE -0 no. TRANSPORTATION ~0 ~0 0.01 0.003 0.050 NASTE MANAGEMENT ~0 0.001 TOTAL 0.22 0.14 0.05 0.004 0.47 +T?ese effects are not included in Table 8-3, 10 CFR 5l. Ref. 7 would indicate about 0.023 *The effects associated with these activities are not known at this time. Hhile such effects are generally believed to be small. they would increase the totals in this column. **Corrected for factor of TD error-based on referenced value (HASH-1250) Ref. Ref. 7 (cl 10 CFR 51. Table 5?3 10 CFR 51, Table 5-4 Ref. 8 - (f Includes milling. uranium hexaflouride production. uranium enrichment. and fuel fabrication. Table lb (Breakdown of Table 1) COAL EXCESS MORTALITY per 0.8 Gwyte) -6l- FUEL CYCLE GENERAL PUBLIC TOTAL COMPONENT ACCIDENT DISEASE ACCIDENT DISEASE RESOURCE RECOVERY 0.3?0.6 0?7 (Mining. Drilling. etc.) PROCESSING 0.04 lO PONER GENERATION 0.0l . TRANSPORTATION 1.2 NASTE MANAGEMENT TOTAL 0.35?0.65 0-7 1.2 13-110 15-120 Ref. 1 *The effects associated with these activities are not known at this time. While such effects are generally believed to be small. they would increase the totals in this column. I I . a 1-- . .nno?p-n?n-nt-u "Oh-muwu?u-o?lable 2. Current Energy Source Summary of Excess Morbidity and Injury per 0.8.6Hy(e) Power Plant Octu ational General Public Totals Morbidity In?ury Morbidity Injury Nuclear Fuel Cycle (all nuclear) . 0.84 12 0.78 0.1 l4 - (with 100% of elec- tricity used by the l3?l4 1.3-5.3 0.55 . 17-24 fuel cycle produced by coal power) (0.5. population for nuclear effects; regional population for coal effects) (9) Coal Fuel Cycle .20-70 17?34 l0-l00 l0 57-2l0 (Regional pupulation) Ratio of Coal to Nuclear: 4.l-15 (all nuclear) 3.4?8.8 (with coal power), Primarily non-fatal cancers and thyroid nodules. - . Primarily non-fatal injuries associated with accidents in uranium mines such as rock falls. explosions. etc. Primarily non-fatal cancers. thyroid nodules, genetically related diseases. and non-fatal illnesses following high radiation doses.such as radiation ""ital"Tra?s?ortaflan?rei?t?d injorl??ifram Primarily non-fatal diseases associated with coal mining such as CHP. bronchitis. Primarily injuries'to coal miners from cave-ins. fires. explosions. etc. (9) Primarily respiratory diseases among adults and children from sulfur emissions from coal-fired power plants. but includes waste coal bank fires. Primarily non-fatal injuries among members of the general public from collisions with coal trains at railroad crossings. 100% of consumed by the nuclear fuel cycle produced by coal power; amounts to 45 ?He per 0.8 Guy Table 2a (Breakdown of Table 2! ?l3? NUCLEAR MORBIDITY ANO per 0.8 'GNyiel ENEL CYCLE OCCUPATIONAL GENERAL PUBLIC TOTAL COMPONENT . MORBIDITY INJURY MURBIDITY INJURY RESOURCE RECOVERY TO (Mining, Drilling. etc.) - PROCESSING 0.6 PONER GENERATION 1.3 FUEL STORAGE ~0 TRANSPORTATION <1 0.l REPROCESSING A. a - -- r- MANAGEMENT I TOTAL 0.84 12 0.78 DJ 14 la! Ref.l (bl Table 5?4, l0 CFR 5l (cl Includes milling, uranium hexaflouride production, uranium_enrichment. and fuel fabication. *The effects associated with these activities are not known at this time. Hhile such effects are generally believed to be small, they would increase the totals in this column. **Non-fatal cancers 3 fatal cancers (excluding thyroid) 0.14 Non?fatal thyroid cancers and benign nodules 3X fatal cancers 0.42 .Genetic defects 2X fatal cancers 0.28? accidents 10X fatalities 0.40 non?fatal cases Normal Operations: Non-fatal cancers 5 fatal cancers 0.064 .Non?fatal thyroid cancers and nodules 3X fatal cancers 0.l9 Genetic effects 2X fatal cancers 0.l3 COAL FUEL CYCLE COMPONENT RESOURCE RECOVERY (Mining, Drilling. etc.) PROCESSING PONER GENERATION FUEL STORAGE TRANSPORTATION WASTE MANAGEMENT TOTAL Ref. I Table 2b (Breakdown of Table 2) HORBIDITY per 0.8 GNerl OCCUPATIONAL GENERAL PUBLIC TOTAL HORBIDITY INJURY MORBIDITY INJURY 20-70 l3-30 i 3 i 1.2 10-100 10 20-70 17-34 10-100 IO 57?2lO *The effects associated with these activities are not known at this time. While such effects are generally believed to be small. they would increase the totals in this column. References 1. 2. id. 11. 12. 13. 14. L.D. Hamilton ?The Health and Environmental Effects of Electricity Generation - A Preliminary Report," Brookhaven National Laboratory (July, 1974). L.D. Hamilton and 5.0. Morris, ?Health Effects of Fossil Fuel Power Plants,? In: Po ulation Exposures - Proceedings of the Eighth Midyear Topical Symposium of the Health Physics Society, (October, 1974). L.D. Hamilton, ?Energy and Health,? In: Proceedings of the Connecticut Conference on Energy (December, 1975). S.C. Morris and K.M. Novak, Handbook for the Quantification of Health Effects from Coal Energy Systems," draft report, Brookhaven National Laboratory (December 15, 1976). "Health and Ecological Effects of Coal Utilization," Draft Report, Argonne National Laboratory (November, 1976). "An Assessment of the Health and Environmental Impacts of fluidized - Bed Combustion of Coal as Applied to Electrical Utility Systems," Argonne National Laboratory, Draft Report (January 25, 1977). "Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Hater Cooled Reactors," U.S Nuclear Regulatory Comission (August, 1976). ?Reactor Safety Study," HASH-1400 U.S. Nuclear Regulatory Commission (October, 1975). ?The Safety of Nuclear Power Reactors (Light Hater-Cooled) and Related Facilities,? U.S. Atomic Energy Commission, NASH-1250 (July, 1973). C.L. Comar and L.A. Sagan, "Health Effects of Energy Production and Conversion," In: J.M. Hollander Annual Review of Energy, Vol. 1, p. 581-600, (1976). D.J. Rose, P.N. Walsh, and L.L. Leskovjan, "Nuclear Power -- Com- pared to Nhat?," American Scientist 64:291-299 (May-June, 1976). D. Grahn, ?Cost-Benefit as Weighed on Genetic scales." In: Energy and the Environment-Cost-Benefit Analysis, R.A. Karan and K.Z. Morgan Pergamon Press, P. 371-386 (1976). "Energy and the Environment," Council on Environmental Quality p. 43, (August, 1973). D.F.S. Natusch, J.R.Nallace, and C.A. Evans, "Toxic Trace Elements: Preferential Concentration in Respirable Particles," Science 183; 202-204 (January 18, 1974). -23- . . 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. S.T. Cuffe and R.H. Gerstle, "Emissions from Coal-Fired Power Plants: A Comprehensive Summary" U.S. Department of Health, Education and Nelfare, Public Health Service, PHS-999-AP-35 (1967). J.E. Martin, E.D. Harward and D.T. Oakley, "Radiation Doses from Fossil Fuel and Nuclear Power Plants,? In: D.A. Berkowitz and A. M. Squires Power Generation and Environmental Change, MIT Press, Cambridge, Mass (1971). I'Air Quality and Stationary Source Emission Control,? Committee 'on Natural Resources, National Academy of Sciences, National Research Council, for the U.S. Senate Committee on Public Norks, Serial No. 94.4, p. 599-6l0 (March, 1975). L.B. Lave and E.P. Seskin, 'An Analysis of the Association Between U.S. Mortality and Air Pollution,? J. Am. Statistical Association Q: 284-290 (1970). H. Hinkelstein, Jr., et al, ?The Relationship of Air Pollution and Economic Status to Total Mortality and Selected ReSpiratory System Mortality in Men: I. Suspended Particulates," Arch. Environ. Health 14: p. 162-171 (January, 1967). I'Mortality and Morbidity During the London Fog of December, 1952,? Ministry of Health, Report No. 95, London, Her Majesty's Stationary Office (1954). H.H. Schrenk, et a1, "Air Pollution in Donora: Epidemiology of the Unusual Smog Episode of October, 1948," Preliminary Report, Public Health Bulletin No. 306 (1959). H. Schimmel and L. Greenburg, Study of the Relation of Pollution to Mortality; New York City, 193-1968," J. Am. Pollution Control Association g; (No. 8): 607-616 (August, 1972). C. Norman, ?Castles in the Air,? Nature 264: 394 (December 21, 1976). L.A. Sagan, ?Health Costs Associated with the Mining, Transport and Combustion of Coal in the Steam-Electric Industry," Nature 107-111, (July 12, 1974). B. Comoner, "the Poverty of Power,? Alfred A. Knoff, Inc. (Subsidiary of Random House, Inc.), New York, N.Y. (May, 1976). J.E. Yocon and N. Grappone, "Effects of Power Plant Emission on Materials,? The Research Corporation of New England, for Electric Power Research Institute (July, 1976). -24- 27. S.M. Barrager, B.R. Judd, and B.R. North, ?The Economic and Socia1 Costs of Coa1 and Nuc1ear E1ectric Generation,? Stanford Research Institute, (March, 1976). 28. D.N. North and M.N. Merkhofer, Methodo1ogy for Ana1yzing Emission Contro1 Strategies," Comput a Ops. Res 3:187-207, Pergamon Press, Great Britain 1976). 29. C.F. Baes, Jr., et a1, "The G1oba1 Carbon Dioxide Prob1em," 0RNL-5194 (August, 1976). 30. R.0. Poh1, "Hea1th Effects of Radon-222 from Uranium Mining,? Search 345-350 (August, 1976). 31. N.N. Denson, et a1, ?Uranium in Coa1 in the Western United States," U.S. Geo1ogica1 Survey Bu11etin 1055 (1959). 32. R.F. Abernathy and F.H. Gibson, "Rare E1ements in Coa1," Info. Circu1ar 8163, U.S. Department of Interior, Bur. of Mines (1963). 33. M. Eisenbud and H.G. Petrow, "Radioactivity in the Atmospheric Eff1uents of Power P1ants that Use Fossi1 Fue1s," Science (1964). 34. L.B. Lave and L.C. Freeburg, "Hea1th Effects of E1ectricity Generation from Coa1, 011 and Nuc1ear Fue1," Nuclear Safety 409-428 (September-October, 1973) 35. ?Comparative Risk?Cost Benefit Study of A1ternative Sources E1ectrica1 Energy" NASH-1224, U.S. Atomic Energy Commission (December, 1974). 36. K.A. Hub and R.A. Sch1enker, "Hea1th Effects of A1ternative Means of E1ectrica1 Generation,? In: POpu1ation Dose Eva1uation and Standards for Man and His Environment, InternationaT Atomic Energy Agency, Vienna (1974). 37. "Interim Report of the Nationa1 Research Counci1 Committee on Nuc1ear and A1ternative Energy Systems," Assemb1y of Engineering, Washington, D.C. (January, 1977) -25- Nuclear power plants. like nuclear bombs. depend on the energy released by splitting heavy atomtc under. A chain reaction occurs when a split atom releases n?'ll?OnS that strike and split the nucleus of another atom But. unlike nuclear bombs. poster plants control the number of neutrons that are asailable in the pro- cess. releasrng only one neutron at a ttrne and absorbing the others. Atom? it. esplosions occur only when many ?ssions take place simultaneously? an impossibility in currently oper- ating power plants [though not in the fast breeder reactor). But no less dangerous atomic ?inA crdean"?radioactne spills and leaks quite possible in nuclear power plants. resulting in the hazardous spread of radioactivity into the sur- rounding area. en langering the lives of plant workers and local residents. and contaminating rivers and farm- land. According to Nuclear Regula- tory Commission estimates. a mirror atomic incident?a core melt- doun?eould release enough radio- activity to contaminate ?13.00? square miles. killing 50.000 people and inturing t. ore meltdown. the ultimate and most serious ptuscr plant disaster. is the overheating and resultant melting vi the "heart" or a nuclear plant?its metal :1 relic-ix and the radioactise tuel they rain. Once the core oser- heats. radioacttse decay continues generating enough heat to cause a tneltdoysn esen if the posser plant has been shutdown "Meltdoun" means. 'lUllc literally. that 'he fuel continues to sink dcunuard by melting artery- thing it touches?including the can .rete floor of the power plant?then retically continuing urttil it reaches tllv.? earth?s graiitational center These fuel pellets. in a tym?ai nuclear plant. contain one thous'mu times the radioactiyiry that was tit 1hr homb dropped on Hiroshima. N'o one kltOt?s esactly how much or radioactiyity would he released and spread during a core meltdown; but men a small fraction of it would .ause the card ?trophe described by the NRC. ?Minor" spills and leaks oc..;r frequently ?wnic p1ant~ steadily leul small amounts ol radioactistts. ushers has-2 suffered ruptured ptpe~ and explosrons that released tern- porary amounts. still other~ has: accidentally spilled thousand- .u callons of radio-attire material i'l" nearby nateruayt And We constant threat til a spam- tadiattori release looms in a niirrh." at existing situations. some of ulitJt have come perilously close to a core meltdown latlures. faults and fires have incapacitated 5 the complex safety mechanisms which 4 are supposed to he safeguards against disaster in the eyent of reactor rial- function. if one of these frequent safety failures had coincided utth a reactor malfunction. a core meltdossn could have occured. Existing inade quate or malfunctioning cooling mechanisms leave many planit with little or no protection against oser- eating. which cauld result in melt down. And a number of plants. sit- ting perilously on seismic faults. could be disabled by an earthquake and suffer core meltdown ?Exempt from safety Big Rock Point Charleston. Michnuclear plants built before [972 present severe hazards because they do not meet even the minimal safety requirements set after I972. Big Rock Point. the fourth nuclear plant butlt In the is a clear exam- ple ()ne of only two plants tn the country allowed to use dangerous plutonium fuel. Big Rock Point has been exempted from conforming to minimal federal safety requtremems ?either because it is classi?ed as "experimental.? or because it is old and small (7'5 megawatts). For exam- ple. cracks have been found in Big Rock Pornt?s core pipe sleeyes. but the plant is allowed to operate With- out replacing the sleeves, Hour-yer. despite its me. Big Rock Point presents a large potential ha:ar.l' lWhile safety standards re- quire 31 least mo water pumps for ctoling in nuclear plants. Big Rock Point has only one pump If the plant's rods became stuck in an "on? position ithey- once stuck in an "off" position). its on-site supply of cooling water would be inadequate to handle the overheating that would result dt't'l'fft'nf waiting to happen Hm hdnan. l' . Consolidated Edison '0 lot nine years. from I966 to 1974. (on Edison claimed that safety- measures needed at Indian Point's L'ntt One would he too expensive. Among many other dangers. Unit (me has no emergency core cooling system and no emergency shutdown system. But the utility refused to make safety changes. even ignoring a 19"] federal order. Finally. in NM. Indian Point's Unit One was ordered to'shut down until emergency safety measures were implemented Con Ed still has not made the changes. and unsuccessfully tried to sell Unit One to the federal government as an Energy Research Development Agency research station. Another problem at Indian Point is the possibility of earthquake dam- age. Units Two and Three operate less than one mile from a seismic fault. and Unit One is directly over a fault. Even though Unit One has shut demo and unloaded its fuel. there is the continuing danger of an earth- quake-caused radiation release as long as the fuel is stored on site. literally hundreds of safety prob- lems have been found at Indian Point's three units Units Two and Three are so riddled with dangers that two NRC scientists resigned last year. citing as one of their concerns the Commission?s refusal to shut down Unit Two Bob Pollard. who jOll'lCd the L'nion of Concerned Scientists after his resignation. called Indian Point "an accident waiting to hap- pen." Several other safety experts hare said that Indian Point. which is located near Netti York City. may be the most dangerous nuclear plant operating today. I, . "L'ndor. and ll ('rn?irres on One has been plagued accidents since it opened it. ICC-0 pipes crack frequently. gas turbine generator has a high rate or failure. salse hase failed. the mac: wall of its reactor vessel ts racked. its emergency condensor has ruptured. it has suffered two uncon- trolled "bloudowns" {severe heat and pressure changes). and NRL scientists hate questioned the ade- quacy of its emergency 'core cooling system In July l9"6. a year after it began operating. Millstone-'5 Unit Two had a total electric failure for five nun- uies If this failure had occurred during. for example. a pipe rupture (when electric power is needed within ten seconds). no safety mechanisms would hate worked. and a caret-melt- down could have resulted. Despite "thorough" checks and tests by NRC. this de?ciency at Unit Two was The I0 Mo ?ange? neyer suspected before the power failure. As a result. the NRC has now begun an investigation of all nuclear plant electrical systems. Millstone's third unit is currently under construction and therefore. said a former NRC scientist. "It's not yet a threat to the lives of Connecticut citizens." But the real scandal of L'nit TTtree is that Northeast Utilities was granted a license to build the unit at all. since the company submitted no construction design prior to licensmg. Northeast Utilities ob- tained its construction permit simply on the "promise" that the design would meet safety requirements. Later. in a renew of other plants that are using the design subsequently developed for Millstone?s Unit ThLee, the NRC found that this design ?does not satisfy those promises." For more information about Mill- stone. see "Red Alert." by Jane Holdsworth in Connecticut. April 1976. ?History of Hush ops emon'l' Yankee lemon. VL. Central Vermont Puhi'tc? Service Corp. A serious disaster at Vermont Yankee uas narrowly averted recently when engineers at MHB Technical Asso- ciates found that the plant's emer- gency core cooling sysrem was im- properly designed and would crack apart in operation. resulting in a major meltdown The plant was closed for repairs?at a cost of $2.6 million to Vermont ratepayers. Another serious problem at Ver- mont Yankee was the plant?s constant emission of which pro- duced high levels of radiation in the surrounding area. including at a near? by school. To solse this problem. an eight-footvthick concrete wall uas built amund the plant?s turbine. shielding radiation from all sides except the plant's riserside. The latest in Vermont Yankee?s long series of accidents occurred in July l?J?o. when the plant spilled into the Connecticut Riser HUI) gallons of liquid mast: containing radioactive. But despite its history of mishaps. \ermont Yankee now? wants to triple its spent fuel storage facilities on site. Indeed. the safe disposal of ever- increasing masses of nuclear wage is a problem that approaches crisis dimensions throughout the nuclear industry. For at least a year. Vermont Yankee has been sharply criticized for its carelessness in trucking nuclear wastes over dangerous roads. driving sometimes in the wrong lane. and failing to notify authorities prior to these shipments. The plant?s owners apparently hope to stem this criticism by keeping nuclear wastes on site. II: IIJ Nuclear. Plants ?Silent leaks" Sorry. Va. Hrginia Electric Power Co. nurry's two units. which represent won 800 megawatts of power. con- tantly leak radioactive material from heir steam generators. There is evi- lence that exposure to this steady tream of low-level radioactivity mitied into the surrounding environ- nent is more damaging to cell mem- ranm?its effects more carcinogeous -than single exposures to larger non? :thal doses of radioactivity. But the JRC pays little attention to these 'insigni?cant" leaks The NRC did, however. charge with making ?material false taiernents? about reactor safety at iurry. and with allowing the use of nfen'or materials and inspection ailures during construction of the ilanl. ?The worst accident ever Decatur. Alta. Tennessee Hitler Author?). On March 22. 19?5. the electrical control cables at Browns Ferry caught fire. causing "probably the most serious commercial nuclear power incident to date." said Nucleonics Week. Billed as the world's largest nuclear power plant t1? million kilo- watts). Browns Ferrywas rushed into operation in August l974?seven months before the tire disaster?des- pite numerous warnings from Atomic Energy Commission safety reviewers and inspectors. who cited dangers of electrical cable ?res. inadequate ?re prevention programs. and poor phy- sical separation of redundant cir- cuitry. The ?re burned uncontrolled for seven and a half hours. destroying and incapacitattng plant safety sys- tems. Workers were able to shut down Browns Perry's L'nit Two: but Unit One was totally out of control for several hours?its sophisticated safety mechanisms completely deA stroyed. Unit One was ?nally put under control with a few piece' 'If equipment that were nor even part of the plant?s safety system. ?By sheer luck." cori?ded TVA nuclear en- gineers. a catastrophic radiation release was avoided. Unit One came within only one hour of a core melt? down. While federal of?cials attributed the Browns Ferry ?re to overlooked hazards. the Union of Concerned Scientists says that "federal safely authorities not only knew about but tolerated serious safety de?ciencies in the Browns Ferry plant in the interest of promoting the forward expansion of the country's nuclear program. For this reason. the Browns Ferry the calls into question both the com- petence and integrity of the nation's nuclear regulatory personnel." (The full UCS report on Browns Ferry is available for $2.50 from UCS. 1208 Massachusetts Ave.. Cambridge. Mass. 02l38.l ?Imminent danger San Clemente. Cat. Southern California Edison Co. The biggest problem in California?~ nuclear plants is the constant threat of earthquakes. San Onot?re's Two and Three were designed to withstand .670 tground accellera- tionl. which is believed to be ade- quate {or expected earthquake acti- vity in the area. But Unit One is al- lowed to operate although ll can ith- stand only .56. Recently. Unit One was shut down not because of the imminent danger from earthquake damage. but for temporary construction work on its dome. Efforts are now underwav to present its reopening until Unll ()ne meets the same earthquake resistance standards as Units Two and Three l0 "Siting carries-sneer Diublo Canyon San Luis Obispo County. Cat, Paci?c Gas Electric Co While California has a history of t? It'- -i"t siting nuclear plants on earthquake faults. Diablo Canyon maybe among the most dramatic example of siting carelessness. It was only after con- struction was completed that Diablo Canyon was discovered to be located smack on a mayor earthquake line. Originally designed to withstand .40. Diablo Canyon will need about twice as much protection to withstand at least .750. Hearings are now being held to determine the expected sever- ity of earthquakes in the area. Pacific Gas 8i Electric Co. then plans to bring Diablo Canyon up to the higher standard and commence operation. boar-mat occurrences 9 lion Zion. Hf. Commonwealth Edtson (to Zion has had the highest rate and number of abnormal occurrences of any nuclear plant in the lit-plant accidents include spilling thousands of gallons of radioactive materials. Zion?s emergency diesel generators fail to work half the lime. and all ?ve generators will probably have to be replaced as a result of their 50 percent failure rate. There are also serious problems with Zion?s emergency core cooling system. which mas not be able to work at full power according to the Adusory Committee on Reactor Safeguards ?Severe contamtnatrrm' ?bro den .Worru. NL. Edison Dresden's two units have crack-x in their primary coolant piping systems, Commonwealth and both units have had tucl failures resulting in extremely high releases oi radioactivity. In addition. nit Took radioactive gas treatment system has exploded several times Dresden's Unit like Zion. dOes not have full emergency core coolant power. and it currently ts contaminated with radioactivity. It will probably have to be shut down soon for decontamination It is estimated that this cleanup will cost more than the original cost of build- ing Dresden. Radioactive spills at Dresden have resulted in several fines by the NRC Finally. in July 1975. the NRC threa- tened to take away the licenses of the two Commonwealth Edison plants (Dresden and hunt because of their .irtri . Lit I?f? uni-jg; rs. .. frequency of accidents. But both plants are still Operating The many "minor" acetdents that oc- cur in these and other nuclear plants. while serious enough in themselses. take on even more ominOus overtones as indicators of the overall unreli- ability of nuclear power plant safety ?the inadequacy of inspection. the dangers that are ignored. overlooked. unknown. or uncontrollable. All these indicators point to what many believe is the inevitability of a core meltdown. The question is not wheth- er a disaster will occur. but when. The Elements surveyed numerous environmental groups and nuclear safety experts to come up with this list of ten highly dangerous nuclear plants There are. we know. mam Other extremely harardom plants not included in our list?for example. Humboldt Bay. Oyster Creek. Monti- cello. Quad Cities. Nine-Mile Point. Pilgrim. YankeevRowe. and others. Scores of groups across the countrv are working to stop the proliferation of dangerous or unnecessary nuclear plants and to repair or close domr harardous operating plants. Virtually all ol these groups are understaffed. undertunded. and overworked. Mara}. of them suffer harrassment from police. public officials. and the nuclear industry. Fe? or them time the time to answer mdtyidual ll'l- quiries for information. but they all would welcome support through donations or volunteer work. local groups and individuals concerned some of the ten plants reviewed here include: Vermont PIRG ch Slate Street. Montpelier. USE-till. the "v?orth Anna ("out (P 0 Box ?ii, Charlotte-~- \il e. \a LWHI Latlteiinc 0mg: Iii.? Harrze! latte. drum. tl'c izimmr merits! -\ctton Council tGrand Ruptdc \lt:hi. inr Nuclear Safeguards til-.14 \letket 9! . Room N19, San Francisco, Ltii 9-1102]. Clamxhell Alliance lbl. Qeabrook. VLJ. and the {New LngIand Coalition on Nuclear Pr-ilu tion {Box 63". Braillehoro. \t Prominent among national group?. concerned nuclear pot-set salt-1i. arc the [man if ('onceiitct! Stren- ll\l\ \Iassachuscth Av: . ('anthriduc. \iass ?Zl?ltl]. I?mttui. (ll-1h Aw. Washington. Elliot. \luwentcn? ?satc and Efficient i nergs (J Bus l) Zl'I'l?i MHH I?hb Aw. l?alu Alto. ('al 943nm. and friend? of the Earth St .Sun Franc-ism. ('al Mi 1 I. Inquiries to federal officials should he directed to Marcus chair- man ot the Nuclear Regulatory Com- mission. and Uncle Mueller. chairman of the Adstsory Committee on Reactor ?afcguards thoth at l'l't' St .N 200551. and to the Jomt Committee on Atomic Energy and the Nurica' Pot-s er hoternmentUperattons Com- mittee tboth at The t. apitnl. Wash- Ington. l) . th?l?l .. .- (11C ucaL uy rumuvmg the source of the problem?~nuclear weapons and all nuclear facilities. But while we work to stop nuclear power, there are some measures that we can take to protect ourselves. The basic rule of good health ap- plies to radiation also: prevention is the best medicine. Although nuclear plants pose awesome radiological dangers, ra- diation from medical sources is gener- ally the major source of exposure to radiation for most of us. And medical x-rays should be taken with the great- est precautions. X-rays kill between 1,800 and 14,000 Americans every year and cause between 600 and 14,000 serious illnesses and disabilities.29 Eminent health physicist W. Mor an estimates that the use of med- ical x-raymsh infr??i tire terse- tngher inithewUS. than inother in ustrialized co ries, could_be"eas? ily? reduced by 90% through using better equipment,oper- ated by trained personnel.30 One obvi- ous step we can take is to avoid x-rays whenever possible, including dental x-rays which are often considered rou- tine. These x-rays give a relatively high dose because they are of low penetra? tion, and are well absorbed by local tissue structures. Fluoroscope examinations may be even more dangerous than x-rays, as doctors tend to leave the machine on longer. There seems to be a connection between long examinations and child- ren?s subsequent leukemias.? The x-ray-like procedure of screen- ing for breast cancer called mammo- graphy has also been revealed to be dangerous. In February 1978, before a ueuuc in medical historf quarter of a million A?m will break out in 15-20 There are fedora glut set allowable iilk, but of the methods used to - .W sampIES disease. Dr. ArthurC. . . lhutmidntl of nuclear of the National Cancer I- -- I. no! alWays reflect admitted tlEat 1the um.- 01 .- hi Md contamination. as screenings or reaslca are will kill women. One milk that 22 women would d" .. I I W?tgted should be screenings for every 116 - a :JChim-se bomb test What price are we willing we "ates ordered possible detection of (may! the shelves and Diet is an importantf flaws? to keep their cows taining human health 1. l' m. these warnings ourselves from the efforts ?"311! was a significant radiation. Radiation con :12? tall! 31 is taken up in the foodclmu- ?3.30; Itryontium-QO. eat large amounts of . twin. products. have been contaminated active particles, the radians. ??rubikllcalthser?iice centrated in the flesh oflhc 2 .. ., am!" that we re- small fish are eaten by Ia . _f 4.31:2 I daily intake of concentration effect cnnli t: small emission of radiation . ll?. [00d we ea .29. oducts and 39.1% or water can lead to sheath .1. . such as wheat and humans and other animals . .oa HI I tive dust can be Cows graze on open - from vegetables by many areas. When thertll at; . advice that was contamination it settles on 1w" - the radio by the Cows will eat the radiation thment of Public . grass,- it becomes concentrM "we . - contamination from milk. The radioactive ?0an I ~05 lest. it is a good t1um?stront1um-90?is I . ?n {i W. another common re- - thlound ateSpecially ,glf .4 ?nal. If cows are pro- . rm milk, their meat is Leg-- - Animals vary in their (?mainly?pigs are six cows.? A diet if 0? high in organically i. mu offer some protec- . 4 int. I9: clients of this con- .Jrei-t" . ..qu . 5 till? . fatigue, headaches, and numbness in hands and feet to boils and loss of appetite. An extra supplement of foods containing these essential minerals?- including calcium?may be a good way to prevent or lessen the effects of fallout and low-level radiation. Here 15 a summary that health writer Linda Clark has made of protective foods and supplements: Foods -?leafy green vegetables ??smooth skinned fruits and vegetables ?protein to build body resistance and energy -?-seeds and sprouted seeds; sunflower seeds ?1iver or desiccated liver tablets or powder . -?oils, vegetable, cod liver and others ?brewers yeast Supplements ?vitamin -?vitarnin complex itamin Be ??bone marrow (can be combined with bone meal in tablets) ?calcium ?magnesium -?natural iodine ?kelp tablets or other sources of all minerals ?lecithin ?pectin (fruits, sunflower seeds 01 other products):16 Another preventative measure is l2( stop?or not start?cigarette smoking It is well known that cigarettes are 2 major factor in lung cancer, but they also amplify the effects of low?leve radiation. "1?1tx? 0 Consumers Power company . Genera! omens: 212 West Michigan Avenue. Jecbson. Micmgan 49901 - Area Code 517 788-0550 August 2h, 1973 Mr. John F. O'Leary, Director Docket 50-255 'Directorate of Licensing License nnp_on United States Atomic Energy Commission Washington, DC 205MB Dear Mr. O'Leary: At 0530 on August 15, 1973, a purge of the .alisades Plant steam generator primary side with dry air was initiated to dry out the tubes and tube sheet to permit inspection for primary to secondary leakage. The plant had been shut down on August 11,1973 to investigate and repair a primary to secondary leak in the steam generator and, at the time the purge was started, was in a cold shutdown condition with the primary,system drained to the hot leg center line. During this purge radioiodine releases via the plant stack were in excess of license limits. The purge system utilized included a furnace type filter on the inlet to the supply fan and an HEPA filter on the inlet of the ex- haust fan. The exhaust of the steam generator purge was vented to the containment building atmosphere which in turn is exhausted to the environment via the plant ventilation stack. This arrangement had been successfully utilized during the last tube repair work in February 1973. However, in hindsight, radioiodine concentrations in the primary coolant were lower in February than they were in August. At 0730 the exhaust from the purge system.was sampled and higher than anticipated airborne Iodine 131 noted. At this point a spare charcoal filter was located and installed (at 1230) on the generator purge system exhaust. The operation of this . purge centinued until 1&00 hours. At 2100 on August 15-, 1973 the charcoal and particulate r11- ters in the stack gas monitoring system were removed and analyzed. These filters had been installed at 0700 on August 11, 1973. Based on analysis of the filters, it was concluded that dur- ing the period between 0700, August 11, 1973 and 2100, August 15,1973 the Technical Specifications limit for release of Iodine 131 had been 5122191; . iHr. John F. O'Leary, Director 2 3 August Bk, 1973 Since the sampler had been in service for a time which was long compared to the most probable period of maximum release, it In difficult to estimate any instantaneous release rate. However, there were other iodine sampling units in service which provided information to enable more precise time periods of release. These samplers were being operated by Allied Chemical, under contract to ABC, for the pur- pose of evaluating generic source term data pertaining to PWR systems. The additional samplers also permitted correlation of data prior to and after the time of significant release. For the time period from 0300 on August ll to 1700 on August 20, . the total release of Iodine 131 was 17h millicuries. With release rate . . data as a function of time interval provided by the various samplers, - correlated with correSponding plant meteorological measurements, site boundary radiation doses were calculated. The maximum integrated life- time thyroid dose to a potential site boundary receptor would have been 0.38 mRem. Site boundary environmental iodine samplers were retrieved and analyzed by an independent party. Their quoted minimum limit of sensi- tivity is 0. 02 pCi/m3 . One site bgundary sampler indicated Iodine l3l concentration of 0. 03_ 0.01 pCi/m Maximum dose calculation based on that concentration at that point would have been 0.02 mRem. Also, a milk sample was obtained from the nearest real cow and analyzed. No activity was detected. [Ehe release was the result of the lack of proper action by per? sonnel in the following areas: Proper attention to the known increase in primary iodine levels since the last steam generator repair work. (E2) Failure to recognize the potential airborne problem and accomplish adequate sampling and airborne containment. Failure of personnel involved to stop the purge once the high airborne condition was realized. In addition, the procedure issued to accomplish the steam generator purge was inadequate in that it failed to provide adequate Operator guidance with regard to sampling. The following corrective action has been taken to preclude 'recurrence of a similar incident: a. This incident was reviewed with the plant staff and shortcomings discussed. b. The purge procedure was reviewed again and changes approved, including required use of a charcoal filter and specific -instructions on sampling requirements prior to continuous purging of the generator. . Mr. John F. O'Leary, Director 3 August 2h, 1973 c. Enclosure tents will be fabricated to contain residual airborne activity when manways are open if access to the primary side of the steam generators in the future is 0 required. . Ralph E. Sevell (Signed) Ralph E. Sevell Nuclear Licensing Administrator CC: BHGrier, . USAEC . . . -1 HAMMOND. IND 80,000 SUN 30 r7 JULY ?30~8/ Protesting hazardous waste Greenggace members chained themselves to the gate at Landfill in Calumet City and Chicago Tuesday, as the environmentalist 7 Xi; 5 Times photo by Michael Zolokowskl ?7 I. group protested the dumping of hazardous materials in the landfill. Authorities arrested 15 people as a result of the demonstration. 502 percent efficiency, it would generate as much electricity as all'our power plants. Cheap Energy. Before we were warned . about shortages, we were told that nu- clear energy would be very, very- cheap; and the believed it. Wrong again. Nuclear plants turned out to be capital-intensive in a time-bf rising capital costs. They experienced rapidly rising costs of uranium fuel and. a declining reserve. They have more ex- pensive construction? costs and operat- ing costs than predicted because of- the mounting awareness of radiation and accident hazards. .The fast breeder and ?ssion reactors promisetohbe more dan- . gerous, expensive,.etc.. Even the 'most ?fervent nuclear critics were n0taware-of of 'these items until the late 19705; the. disappointing performance- of nu- clear plants has Surprised-even} their enemies. - . Radiation Hazards. The official posi- tion on this has been steadily eroded.- Permissible limits of-Jexpo'sure for work'- ers and the public have been revised downward two or three times as more. information comes in'. '(Sometimes- that information was initially dismissed and . discredited by the Government.) Indus- try and the Government still have ?not accepted the position that no increase in exposure, no m'atter.how? trivial, is 'safe because we can barely tolerate natural radiation now. Furthertnore; it is well documented that radioactive materials, accumulatein successive? stages of the food? chain, so what is? trivial in water? ends .up as significant in human beings. The genetic burden?here to stay?of 'nuclear power is beginning to be recog- nized- Yet radiation dangers ,were denied. a scant twenty years ago, and data were even suppressed in some un? seemly' actions: by. the. Government, which are well documented in all the books of the last 'few years.? The latest fear "is that radiation ?undetectable by current devices. is contaminating the food, land and people around nuclear plants. . . Accidents. As with the other issues, the full dangers could reveal themselves only as we accumulated experience and evidence,- but the Government and the industry suppressed some of the evi- ., NEXT WEEK: -. i 'TheNaiion. dence and ignored much more. Their opponents have been digging it out with? the help of the Freedom of Information Act; Technically, no one has died- as an immediate result of an' accident in a commercial plant, but many have died from accidents in Government and ex- perimental plants and at other stages of the fuel cycle; thousands more have re?- ceived dosages that will shorten their lives. In addition, accidents have poi- soned water supplies and 'will continue to do so since the waste cannot be safely contained. 1-. - -. - Reactor accidents ?deservega special. ~n?ote as we celebrate the anniversary of almost losing a_ good part of the Eastern- Seaboard. Webb?s account of the acci- dent. at 'the end of Nuclear Lessons pro- vides it..It is'technical, but not impos- sibly so, and the effort to follow it will be rewarding. His main points include these: contrary to the claims of the in-_ dostry, the at T.M.I. did :1 not all work; disaster. was averted only ?by bringing in'-eqitipment from the out- side, jury-rigging, equipment, and using- it for purposes for which it was not de- signed. We came close to complete. core' melting and the {resulting steam'explo- sions at several points. One lucky break that helped save Us was that a pump and a gauge, being used for forced cooling of the whole core, even though they were not designed. for this, managed _to. keep working for some weeks. Two other identical gauges failed early on, since they werelnot designed to with- stand all the radiation, but this one just happened to last; and allowed the pump to continue, which also. just happened to last. Without1 them there. would very likely have been a . . . the spark. liad set off the hydrogen explosionthirtyiminutes or so later than it actually did, the explosion would have.- been much bigger and could have darn- aged crucial eduipment.. If Operators had to abandon Unit 2, Unit 1 would have melted down because of loss of controls, of power, of radiation damage to equipment, etc- That unit, older than Unit 2, probably has about 100' Hiro- shimas in it..ln fact, if the accident had occurred there rather than in Unit 2., the enormous amount of radioactivity could have made it totally unmanageable. Reactor accidents follow the same scenario as the other issues we have been discussing?they couldn?t happenhad some more, culminating in and the Government and the industry promised to clean up their act, while noting - that proved 'nuclear power was safe. The Kemeny Commis- sion scolded all concerned but said that if they did their job right the risk would be tolerable. The critics don't think so, but their attack- in this area is not as sharp as it could be. They could draw upon the work of Webb and nail the ac- cident point down ?rmly. In a. 1976 book, The Accident Hazards of Nuclear Power Plants, Webb pointed out that most of the serious accidents cidents (there werenvelve in the country .by then; about six more since. then).Were the resin: of': multiple" had- at least?fiye signi?cant multiple. failures. . Actually, 'the major' is:not just - multiple? "if "these are in- -a comprehensible sequence .the operators . and safety systems may cope. It is when- - we have multiple failures that are inde- pendent of one another??it just- so happened thatwhen-A failed, was in- . they are in danger of being incomprehensible to. the'opera- tors. This was the case at and numerous other'accidents (though not all) in nuclear. and otherihigh-risk sys- tems. In this. case it is the-complexity of the system that ?causes" the accident. - Since we. expect equipment, operator and procedure errors, since -nothing_,is perfect, we design safety systems -. to= . cope with them: +But..if independent; multiple failures just happen to occur or be present at the same time, and they in: - teract, as they will in a complex system, the cause of the accident lies in the com; plexity and. interdependence of: the: sys: tern itself. It is,'as I have. labeled-it, a ?normal accident,? bound to happen some time (not often); dif?cult to cope with, unpredictable and unpreventable, ;The normal accident case of nega- tive synergy) is a notion nuclear critics might pro?tably use. They can then say; Even. if every- extravagant thing the Kemeny Commission asked for were to- take, place (responsible bureaucracies; public interest capitalism, etc.) the risk of a catastrOphic accident would not be greatly reduced. Normal accidents. are bound to occur in all our complex, coupled high-risk systems which we have been persuaded that we need, from. towering infernos to recombinant DNA research. Nuclear power. plants Apri12t1j980' o. . tilt-45?s?. assignment-i1. . v, I E'rr' I ln'. .1 En?: . - at! rate.- . A nf?m 7 - - SPRING BOOKS ISSUE - .b a few did, so we ?learned? from them- ?(along with, nuclear weapons) just hap- - andthat made the we. pen to be the mostlethal. .41. . e1 . J. .. -I. ARTMENT OF ZOOLOGY CH nucnusArs .5 :llfl' .?rsJ ARBOR, ?18104 rump. 1:1 'o-euu' October 16, 1974 STATEMENT OF PROFESSOR T. M. RIZKI CONCERNING THE BIOLOGICAL EFFECTS OF Most of the tritium entering an animal body is eliminated. However, a fraction of the tritium that is retained in the biological system enters the'DNA of the proliferating cells by specific metabolic pathways. Once tritium is incorporated into DNA, the genetic material of the cell, this cell is then subjected to a highly selective irradiation. It should be stressed that the genetic material within the cell nucleus is the most radiosensitive target in the cell, and radiation within the confines of the cell nucleus can therefore produce pronounced damage. As a consequence of this damage, the cell may die; but this may not be too harmful to the organism since some cells die in the normal course of events anyhow. The cells that survive and have been genetically damaged offer the more frightening consequences since these cells may no longer represent a normal, harmonious part of-the living body. A safe prediction concerning_the effects of genetic damage to somatic cells in man would be an expected increase in the incidence of various kinds of cancer. Evidence of genetic .effects_and cell lethality caused by tritium have been demonstrated in a variety of organisms by scientists over the past decade. In View of this information, it becomes prudent to consider the potential damaging consequences of increasing levels of tritium in our environment, particularly under circumstances in which this radioactive isotOpe can readily enter the food chain cycle via organisms, as well as by direct contact with moist body surfaces. As a biologist and geneticist, I would like to point out that there has been a tendency to underestimate the damaging effects of tritium. In considering radioactive materials in terms of energy levels, we are often misled by assuming that tritium is a weak beta?emitter. Our thinking must be altered; we must underline the fact that once tritium is incorporated in a biological molecule such as DNA, the degree of concentrated ionization within a hundred~thousandth of an inch is so high that to achieve the same effect from background radiation would require enormous amounts of deep penetrating radiation. JG 2 Statement of T. M. Rizki Therefore, the effects of tritium on living systems require an especially careful reevaluation. Nature has provided the human body with mechanisms to repair 'various kinds of damage: by replacing dead cells with healthy cells; by regeneration of tissues to heal wounds; by repairing some of the broken DNA molecules. However, the repair of damage depends upon the internal environment of the body, and it is known, for example, that the presence of certain chemicals such as some of the antibiotics and caffeine can block the repair activities for DNA. Furthermore, radiation induced double-strand breaks of DNA, or loss of small pieces of DNA following radiation damage, cannot be repaired to form normal molecules, and this is an additional reason why increased levels of tritium in our environment will have damaging effects on living systems. Experimenters on both sides of the aisle can easily come up with "detectable" or "not detectable" damaging effects of tritium radiation-by simply manipulating the dose levels of tritium and the conditions of the experiment. It is because of this fact that I feel it is essential that we have positive evidence of the existence and operation of molecular and cellular mechanisms in the human body whereby cells of the body can be protected against the damaging effects of incorporated tritium. Our biological know-how has reached the point where we have broken the code of life, we can manipulate genetic material from one organism to another. Is it, in this day and age, too much to ask that we thoroughly investigate the biological mechanisms of safety against tritium effects rather than rely on statistics of positive and negative correlations? In the meantime, some degree of caution would not be amiss. For man is, after all, governed by the same laws of nature that rule those living organisms in which the harmful effects of tritium have been experimentally demonstrated. 5"llifel? I. .r Gar-om! omccs: 2?2 \Vesl Avenur. JuCkE-on. mudgnn 4030! . Arne Code 517 703'055t January 26, 1973 'Mr. Boyce H. Grier Re: Docket No United States Atomic Energy . License ho Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Dear Mr. Grier: Your letter of December 21, 1972 stated that the Pelisadcs Plant was in noncompliance with AEC requirements; that gas? eous waste may have been discharged directly to the stack for a period of several months which exceeds the allowable time for discharge of th waste gas surge tank directly to the stuck. This letter will apprise you of the-action that has been taken to improve the waste gas system performance such that the requirements of Article 3.9.1? of the Teehni cal Specifications can consistently be adhered to. During the early operation of the Palisades Plant (January and February 1972), evaluation of the performance of the waste gas was difficult because of excessive gas collection fron'systems requiring the use of cover genes as well as ,es collection from the many plant start?up: and shuLdouns. During this time, it was difficnl to achieve the required seven-day holdup time in the doc:? tents end, in addition, it was suspected that the decey relief valves mere leaking. The relief valve wes modified to provide ease of maintenance and the relief velven were reset end lapped. Also during this period, the exce?sivc gun collection problem was reduced somewhat. Following the work on the relief Yu_?v5, it was concluiee that leekege still existed from the decay tents. In April 3972, all nine deeqy tent inlves were renewed, reworked and re? ?installed in en attempt to stop the lenknge. During Hay and June 19?: valve pnehinas were continuously heir; reverted to prevent leuktcc. (he: collectiini rates \nrre still_txacensi\e, not expez?? cneca early in the year. Even so, radioactive ?ns collection only represented an estinetcd 20$ of the noses we were trying to hold up. The total gaseous activity released during the fi'st half of 1972 was very low. . '10 II..- ?43IIollI I 1' - - villi:Il'I?ll-l ?I"ll I II I ll?ll j' Ii .: I I. l"'i1: :I?ll? II I1: I I: - :IllIllII- t?ifi 115a9 . 5/74?Va: I 9 Wm ask/uum{ I WW $71125? Mm? Ma 7 776w ., fun?4M "254/144 I E. a? ,vata mm $5 .. ombR?tx bgsami {gt} .. hair?. KSJ i - bit: (mmx?P m, cg?gm iv. .. kfom Q. $3ng 7? RIGID NICHISAN DEPT OF NATURAL RESOURCES ENVIRONNENTAL LABORATORY YES - INFO ON BACK NATRII I HATER ANALYSIS REOUEST SHEET SAFE NARNINS I I LAB 7.163 PROJ 31:21:10, COST I RECEIVED 0411;: (13?13;? LORI can: CENTER PR AT LOCATION 7 - COLLECTED 18 3y .. Sing SAHPLE - SEND INANE ELAS USE ONLY FIELO.ID OR DESCRIPTION SAMPLE INFORNATION I YYINNIDD I I I I I !059035 ORGANIC INORSANIC GENERAL CNENISTRY POI HAD FIELD DISS ARONATIC rv--RES-RES-eno'f?sjfm'ay. 13345579910 12345523910 DAYBOD CARE 5 DAYOTHERS (CIRCLEPHENOLSTOCFURNACENH3KJEL NI TDT . 5 6;!58 9 IO- OIL I 6REASE-6RA9..9:ALKFLOORIDE TOTAL FREE HCO3-DISSFECAL TOTAL BRINE ICIRCLEI ALK HCO3- CO3-.. HICHIGAI DEPT OF NATURRL RESOURCES EHVIROIHEITM LABORATORY HATRII a HATER BEHEIAL CHEHISIRY ZIBI LAO PROJ cosr /7 I 6 LOGO "24(9-3? cons CENTER PR mama DME REPORTED LOCATION SAHPLED cannms OXYGEN ORTH N02 RES-NF TURB. E.0.0. LAO IO. OISS TOTAL 55-105 105180 TOTR. HACH LOU HSIL HEIL HBIL NEIL HSIL FTU HGIL 00300 70507 00615 00530 70302 0310 000?6 00335 I E;q 7.7.T.O.C. NOTINUZ H03 IH3 KJEL 006 PHUS. PHEHOL CH FECIL 1 TOTAL 3 TUTRL 1 TOTAL 7 TOTRL TUTHL T. REE T0101 CULI H511 NEIL 1 HSIL "5/1 HSIL HGIL UBIL NEIL HF. 00600 00630 00620 00610 1 00625 1 00605 00665 32730 00720 31616 '31. 2-06 I v.0 '94, .- - o-o .- o-I?onu- - - .s . a EL066 lu? 9 10" odI 1".ul :69 man w-u f??l MICH DREHHIC .85 {urtolbl? 52. .64 .39 .5'3 .25 .33 mafL pr - I ED I31 UFKL nab I El IEI HafL D?b U1 El Unlesa n?tEd periormed For DHH EHVIRDHMEHTHL HESULTE FUR LHE L06 #7 4H CDMMEHTS Detection limit SDHH 3 COMMENTS limit Sti?n 3 CDHHEHTS DR IHT H.85 1FEF4 4F . 1. INT i1 limit E"Eh1??ph Detectimn limit all others 6 COMMENTS EH UHID PEHKS limit molar pesticides limit Rhth?l?tes Detection Detection CUMMEHTS ?etection limit ECHH CDMMEHTS LH LP Detection limit CDNHEHTS: an attached Faun analyses were list. above the Concentratimna are rounded t0 2 :iFhificunt Figures. JAM 1 0 1986 L05 1 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 7433 RESULT CODES: =Less Than; LAB A 54777 54777 54777 54777 54777 54777 54777 54777 54777 54777 54777 54777 54777 5A777 54777 54777 54777 54777 54777 54777 0 54777 54777 54777 =Interference: PARAHETER ALKALINITY ARSENIE BERYLLIUH ALK, 003: 0003100 CHLORIDE 000017 00003103 007753 003000710177 IRON ALK, 0003? LITHIOH HANSANESE NICKEL LEAD PH SULFATE ZINC CALCIUM 707055103 HABNESIUH 500103 HICHIEAN DEPARTMENT OF NATURAL RESOURCES ERVIRORHENTAL LABORATORY INOREAIIC 0517 ANALYTICAL RESULTS CODE VALUE UNITS 255.0 33.0 20.0 5.0 20.0 185.0 35.0 370.0 230.0 1,724.0 137,000.0 255.0 340.0 3,100.0 230.0 310.0 HT 7.3 323.0 330.0 223.0 23.0 25.1 75.1 =H0)ding Tine Exceeded; =lnsuf7icient Sample; H6 7 (ppm) Tpph) UBIL lppb) HO I lppb) RE I lppl) Tppb) UBIL Tppb) {ppb) UHHOSIEH (pph) NO I [pme OOIL Tppb) (ppb) UOIL (pph) UBIL {ppb) PH H8 Tppl) UGIL Tppb) HG I {ppn) HE (ppm) MB 7 (ppm) HO 7 Tppn) =P055ible Interference; =00 330019 Received: =Lah Accident; ANALYSIS TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL TOTAL DISSOLVED DISSOLVED DISSOLVED DISSOLVED HATRIX HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER HATER =N0t optiAUI Dilution RUN i 302 256 00753 79 00752 302 00752 00753 00752 207 00752 79 00752 00752 00752 00752 207 302 00752 10900 10900 10900 10900 =Not Available 5137417457. NW n?r- Tbursdap, November 15. 1984 By JULIE MORRISON --Daily News staff writer MOUNT PLEASANT The Dow Chemical Co); . - contention that two dioxin ?hot spots? found on its Mid- ?laiid plantsite are up threat to the public an environmentalist whohved in the Love Canal area ofNew?Yoi'kEaYd Wednesday. - Loi?s Marie Gibbs, who became president of the Love Canal Homebvmers Aesociaton near NiagaraFalls alter chemicals, including dioxin, were found to be leak- ing into water-supplies, said Dow is minimizing the danger of the chemical because of its ?vested interest? in selling products. ?Dow's claim of no threat to the neighborhood is baloney." Mrs. Gibbs said at Central Michigan Univer- sity. ?if Dow is correct, then why does Midland have a ?no and a half times higher than national average of and tissue cancer? "That information (that there is no health threat) is put out by people who have something to gain.? she said. ?That is the sale of their product. ?It?s not because the Dow Chemical Co. management Midland Daily News. Midla nd, Michigan Speaker: Do w?s? dioxin assurances are ?baloney? are because they have a vested interest,? she continued. "They?re not evil, they just want to make money. And aswe know, money is the root of all evil.? Two spots ofdiaxin contamination, measuring34 and 52 parts per billion. were found-on the Dow plant site as 'f?pertofa'dioxin - excee?dlheresidential lev of cal company. concern of 1 ppb?established bythe federal Centers ?ar Disease Control. That standard includes a provision as- suming a person would eat 10 grams of contaminated . soilseverydayfor'lyears. - The dioxin found was the 2.3.7.8.TCDD isomer; ?re most hazardous known. The chemical is an unw reductpf other chemical processes. claims the dioxin levels are not a health tin-eat because theyarein an isolated areawithin theplant accessible to. workers. The company also said one te . has been covered with asphalt, which Mrs. Gibbs said does not reduce the health threat. ?l've heard of covering it up, but they're makingi a bit obvious,? she said, adding the contaminant can . carried through soil, blown in the wind and is being sent into the Tittabawassee River. 3 Mrs. Gibbs, .who now lives in Virginia, founded the Citizens Clearinghouse for Hazardous Wastes in Ar- lington and said she decided to help other communities fa?cing chemical contamination after her experience in New York. Her son and daughter both experienced said.?and her daughter has been diagnosed sis-having leukemia. Fifty-six pecent of the babies born in what became known as the Love Canal area had birth defects and the area had the highest rate of miscan'iag?es and cancer in the state, she said. Mrs. Gibbs? comments about Dow and Midland. set off anangry exchange between her and a Dow employee attending the lecture. Cathy Schaner contended the i ndlogy to reduce dioxin contamination. just trying to state Ms; Schaner said. ?Lwish she (Mrs. Gibbs) had done that?through her whole speech.? Mrs. Gibbs said Midland and Times Beach. Ma. acity evacuated because, of dioxin contamination, ?are run- ning neck and neck? as areas with the highest levels of - chemical company leads the nation in developing tech-. Section Page 3 the chemical. Ms. Schaner argued Times Beach had di- oxin levels 2,000 times higher than here. ?She's obviously very bitter about what?s happened to her and refusesto see both sides," Ms. Schaner said after the speech. Ms. Schaneralsoaccused Mrs. Gibbs of"bel- ittling? data she presented. Also attending the speech was John Davidson. a Dow retiree nicknamed ?General Davidson of for his work developing the herbicide. That herbi- cide as combined with another to make Agent Orange. a dioxin-containing defoliant used during the Vietnam War. - Diane Hebert and Andrea Wilson, founders of the Environmental Congress of Mid-Michigan. also at tended the speech and were praised by Mrs. Gibbs for their efforts in publicizing dioxin. She said more of the public will have to act against the chemical con- "I?he EPA (Environmental Pinteetion Agency} bud- get'bas been 'cut to almost nothing," she said, ?anli under this administration. unfortunately, the EPA is the Dow Chemical Co.? ENT REPORT 06? 7/ 1375 ,onic Injury Surveillance System reports nor the .jual Clearinghouse for Poison Control Centers generally provne information on the size of the container of the product involved in the ingestion. In summing up its position, the directorate said it believes that it is highly unlikely that substances for which there are standards are customarily produced or distributed for sale or use or stored in or about the household. In no in- stances familiar to the directorate are there hazardous sub- stances subject to the standards and in containers of five?gallon capacity or greater which are customarily sold for household use. The directorate said it believes such sub- stances are not subject to the standards and require no "exemption.? Solid Waste EPA WITHOUT POLICY TO DISCOVER IMMINENTLY DANGEROUS WASTE SITES The Environmental Protection Agency apparently has no policy to discover new imminently dangerous hazardous waste disposal sites in the US, according to EPA testimony presented October 30 before a House subcommittee. At a hearing of the House Commerce Subcommittee on Oversight and investigations. Hugh B. Kaufman, manager of the assessment program in EPA's hazardous waste manage- ment division, said he was ordered this past June to stop look- ing for imminent hazards. Kaufman said his duty is to administer Section 7003 (im- minent hazards) of the Resource Conservation and Recovery Act (RCRA). and be focal point and lead office in assessing environmental and public health damages caused by hazardous waste management practices in the US. He said he has no budget and only one employee to carry out this responsibility. A June 16 memorandum from Steffen W. Plehn, EPA deputy assistant administrator for solid waste, to John P. Lehman, director of the hazardous waste management divi~ sion. ordered Lehman to have Kaufman ?put a hold on all imminent hazard efforts," saying that work on the Subtitle (hazardous waste) regulations has higher priority ?at this time.? Asked by Albert Gore, Jr. (D-Tenn), who was chairing the subcommittee hearing, if it is policy not to identify im- minent hazardous waste dangers, Thomas C. Jorling, EPA assistant administrator for the Office of Water and Waste Management, said. ?It is not our policy to keep the agency from identifying imminent solid waste hazards.? He said priorities on solid waste are to issue the hazardous waste regulations and to respond to imminent substantial hazards has not been given high priority, but he said resources for enforcement regional staffs may be increased next year. Don't Discover New Sites Jorling apparently reaffirmed EPA's policy not to identify and discover new imminently dangerous hazardous waste disposal sites in an October 2 intra-agency memo. The memo directed EPA regional administrators to inven- tory and supply EPA headquarters with information on known hazardous waste storage or disposal situations posing a current or potential hazard to public health. The informa- tion would be given to an Office of Management and Budget task force assessing the potential magnitude of Love Canal lime incidents and developing various options for federal Done)! in handling these incidents. 11-378 The Jorling memo said,?lt is not expected that EPA make any efforts to 'discover' sites (through field visits. substan- tial file searches, or other means) for which we do not currently have information. Rather. it is expected that EPA make estimates based en knowledge about present and past industrial activity and present and past disposal practices in each region. ?incidents included in the inventory should be situations for which you have more than circumstantial information, the public (at least locally) is already aware. and publicly accessible information is already on file." Kaufman noted that before passage of RCRA, had a vigorous program to find and assess damage from hazardous waste facilities.? After the Act was passed, however, Kaufman said that regional offices asked that no more damage assessments be made. Imminent Hazard Functions Transferred Jorling said the reason Kaufman was ordered off hazar- dous waste assessments of imminent hazards was that the function has been transferred from Kaufman?s office to the Office of Enforcement. A May 15 memo from Plehn to Lehman referred to EPA's transfer of imminent hazards to the enforcement office. The memo said the enforcement office was drafting guidance to its regional offices to reflect that: The Office of Enforcement would have lead responsibili- ty for imminent hazard situations both at headquarters and in the regions; and. The Office of Solid Waste would serve primarily as a source of technical expertise in supporting the Office of En- forcement. The memo said any imminent hazard information brought to EPA's attention should be passed to Richard Wilson, depu- ty assistant administrator for enforcement. Kaufman said that this memo did not stop him from look- ing for imminent hazards, and he continued to make his damage assessment. He said, however, that at a June 15 hazardous waste divi- sion meeting, division director Lehman said that the Carter Administration?s policy for hazardous Waste had changed, and the Administration was going to cut back the hazardous waste program as it existed. The following day, Kaufman received a copy of the Plehn memo ordering him to stop looking for new imminent hazards. Kaufman said he was told not only by headquarters, but also by EPA regional offices, to stay out of their regions in investigating potentially dangerous hazardous waste sites. RCRA Imminent Hazard Authority The Office of Enforcement, specifically the pesticides and toxic substances enforcement division. will be responsible for administrative and enforcement aspects of hazard situations, according to an October 10 memo to regional hazardous waste division directors. The memo. from A.E. Conroy, director of the pesticides and toxic substances enforcement division, and from hazar- dous waste division director Lehman, outlined interim strategy for RCRA hazardous waste violations. According to the memo, RCRA Section 7003 is the only available enforcement mechanism under the Act intended to deal with emergency situations presenting an "imminent and substantial endangerment to health or the environment." Jorling said EPA believes Section 7003 of RCRA authorizes the agency to take enforcement action against the owner of an inactive site if the site is presenting an immi- Copyright 1978 by The Bureau of National Affairs, Inc. OMB-79735783500 50 6 CHEMICAL REGULATION REPORTER ?t and substantial danger to human health or the environ- t. He said the agency could effectively exercise this an why when the present owner is in some way responsible for the danger and is financially able to remedy it. He said. however. that the section is not an effective tool for abandoned sites. Reporting SUBSTANTIAL RISK NOTIFICATION DECEMBER MEETING SCHEDULED BY EPA The Environmental Protection Agency announced it will hold a public participation meeting December 7 at the Skyline Inn in Washington to discuss implementation of Section 8(ei of the Toxic Substances Control Act (43 FR 50503). A panel of EPA members will explain the current status of 8(a) implementation and will conduct a discussion on issues and questions submitted in advance by the public. The agen- cy requests that questions refer to specific problems or issues encountered in interpreting 8(e) policy. To submit questions or discussion issues concerning TSCA substantial risk reporting contact Charles M. Auer. Assess- ment Division (TS-792). Office of Toxic Substances. US. EPA. 401 St. S.W.. Washington. DC 20460. For further information contact the Industry Assistance Office. toll-free number (800) 424-9065 or in Washington. DC, 554-1404. To date the agency has received approximately 150 sub- stantial risk notices under Section life) of TSCA. General Policy ATSAC REGISTERS DISAPPROVAL OVER DELAY IN SECTION 5 GUIDELINES Disappointment was expressed by the Environmental Protection Agency's Administrator's Toxic Substances Ad- visory Committee that no premarketing test guidelines are being issued with the Toxic Substances Control Act Section 5 proposed rules and draft notice form. In an October 25 memorandum to EPA assistant ad- ministrator Steven Jellinek. the committee members stated that the guidelines could be of great benefit in telling in- dustry what information is expected. in minimizing decision- making which Would have to be done on a chemical- by-chemical basis. and in assuring that adequate testing would be conducted for the full range of relevant effects. As Section 5 guidelines will not be prepared with the draft notice and rules. the committee recommended that the in- itial package require information on all effects of concern. that guidelines still be developed. that mandatory test rules be established for chemicals by category under Section 4. and that the agency provide testing assistance if economical- ly needed. Several of these recommendations parallel resolutions made by the ATSAC at their last meeting September 29 (Current Report. October 6. p. 1177). Kotonoa NIOSH URGES REDUCTION IN LIMITS: CRITERIA FOR STANDARD AFIE RECOMMENDED Reduction of current federal limits for workplace ex- posure to certain ketones was recommended to the Labor 11-3?78 Department by the National Institute for Occupational Safe- ty and Health. The criteria document in which the recommenda- tions appear suggests the following limits for ketones: Approximate mg/cu equivalents Acetone 590 250 Methyl ethyl ketone 590 200 Methyl n-propyi ketone 530 150 Methyl n-butyl ketcne 4 1 Methyl n-amyl ketone 465 100 Methyl isobutyl hetone 200 50 Methyl isoamyl ketone 230 50 Diisobutyi ketone 140 25 Cyclohexanone 100 25 Mesityl oxide 4O 10 Diacetone alcohol 240 50 lsophorone 23 4 The institute noted that exposure to ketones can cause local effects such as irritation of the eyes, upper respiratory tract. and skin. and systemic effects such as peripheral neuropathy from methyl n-butyl ketone. Solid Waste HAZARDOUS WASTE UNIT WOULD BE REPLACED BY INDUSTRIAL DIVISIONS IN EPA REVAMP The Environmental Protection Agency is considering reorganizing its Office of Solid Waste to create two in- dustrial waste management divisions in place of the current single hazardous waste management division that exists at present, and to combine the other two OSW divisions into one. Plans for the reorganization are contained in an October 27 memorandum to senior OSW staff from EPA Deputy Assis- tant Administrator Steffen W. Plelin. The memorandum says the reorganization is intended to deal with an ?im- balance" between the present hazardous waste management division and the other two OSW divisions. resource reCOVery and land diSposal. Under EPA's 1979 operating plan. the hazardous waste management division has 50 positions and a budget of $3.4 million. The land disposal division has 33 positions and $800.000. and the resource recovery division has 31 persons and 5500.000. excluding the panels that provide state and local governments with technical assistance on solid waste problems. One objective of the proposed reorganization would be to "enable the integrated development of technological control requirements for both hazardous and non-hazardous in- dustrial wastes by a single organizational unit.? Plehn?s memorandum says. Sewage Sludge The memorandum says nothing about recent controversies within EPA about how to mesh hazardous waste rules with those on land application of sewage sludge. . Some EPA of ficials'are concerned that an standard would eliminate incentives for municipalities to dispose of sewage sludge by land application. but hazardous Chemical Regulation Reporter 0148- 79730850050 take issue with EPA proposals States may have to go it alone in provid- ing secure sites for disposal of hazardous materials. That appeared to be the consen? sus of some 300 ol?cials from 29 states at last week?s International Conference on Hazardous Materials Management in De- troit. Besct by local opposition to new dispos- al sites and the failure of the Environmen- tal Protection Agency to mow: swiftly to implement the Resource Conservation and Recovery Act. some states are planning to act without waiting for federal guidance. For example. Michigan already has plans for its own disposal complex. including incineration (CW. Sept. 27. p. I5). Said Michigan Governor William G. Millikcn: ?The force of events . . . [is] casting the states in a primary role in initiating the resolution of the manage- ment of hazardous materials." Local Incentives: To get around the problem of local oppositiou to disposal sites. William DcVille. staff chairman of the National Governors? Assn. subcom- mittee on waste management, suggested the establishing of ?some incentives or inducements." But a source of funds for such induce- ments is likely to prove hard to ?nd. Thomas C. Jorling. assistant administra- tor of EPA's Ollice of Water and Waste Management warned of a tight federal budget ahead. He said increased funds are available for such new programs as hazardous-waste disposal and toxic-chemi- cal control but this must be ?at the .- Michigan's Millikan: states play pllm?ty l'Glc. expense of older programs." Meanwhile. El?A's draft proposal for de?ning hazardous wastes (CW. Dec. 6. p. 49) came under ?re at the meeting. Geral- dine V. Cos. biological activities coordina- tor for an American Society for Testing and Materials subcommittee studying the EPA proposal. calls the agency's recom? mended leachatc test "an untested. pat- ented mixing chamber which was develop ed solely for this test." The c0nference outlined a number of areas for action by the National Gover- nors? Assn. when it meets in February. 1979. These include adoption of a consist- ent state position on RCRA. development of methods to speed the investigation and surveillance of hazardous waste problems across state lines. support for federal legis- lation providing compensation to victims of hazardous-waste disasters. and encour- agement for modi?cation of Toxic Sub- stance Control Act (TSCA) provisions preventing disclosure to states of chemical substances manufactured within their boundaries. The goal of the actions taken at the Michigan conference. or proposed there. says Michigan Natural Resources Dept. Director Howard A. Tanner. is to avoid state strategy of ?when in danger or in doubt. run in circles, scream and shout." OSHA plans action on epi, vinyl bromide and ethylene dichloride The Occupational Safety and Health Administration is seeking information to determine if it should regulate as carcino- gens widely used chemicals?epi- vinyl bromide and ethylene dichloride. The agency is contemplating taking regulatory action on the com- pou'nds. OSHA is particularly concerned about epi as the result of two studies. An inhala- tion study underway by Norton Nelson of the New York University Institute of Environmental Medicine found that 13 out of I40 rats exposed to l00 parts per million of epi died of nasal cancer. And a study of workers exposed to cpichlorohy- drin at two Shell Chemical facilities also roused OSllA?s concern. The epidemio- logical data. Which was analyzed by Philip of the University of Pittsburgh. showed that the number of cancer deaths exceeded the expected total (CW. Aug. 16. p. lithylene dichloride (also known as is suspect as the result of tests conducted by the National Cancer scintillation-me Institute (CW, Sept. 27. p. l8). OSHA says. Oral administration of the compound produced forcstornach cancers. vascular- izcd cancers of multiple organs. and cancers beneath the skin of male rats. Eth- ylene dichloride exposure resulted in breast cancer in female rats and mice. uterine cancer in female mice and respira- tory tract cancer in male and female mice. But studies by Cesare Maltoni at the Institute of Oncology (Bologna. Italy) appear to contradict the NCI ?ndings. As for vinyl bromide. a study by the Huntington Research Center indicated that rats exposed to 50 ppm. vinyl bromide developed angiosarcoma of the liver and other tumors. and those exposed to 10 ppm. developed angiosarcoma of the nodes. The National Institute for Occupational Safety and Health had previously recom- mended that two of the three substances? epichlorohydrin and vinyl bromide?be considered human carcinogens (C W. Nov. 1. p. 60). Meanwhile. has issued special reports on the toxic effects of the pesti- cides DDT. aldrin and dieldrin. and on a cur- ing agent for urethane clastomers. The agency reported that aldrin and dieldrin have ?considerable potential for carcino- genic effects in humans.? and noted that the two pesticides caused cancer in mice in 20 experiments. In the case of dieldrin. dietary doses as low as and 1 ppm. caused ?signi?cant" increases in both lung and liver tumors in mice. NIOSH recom- mends that exposures be limited to 0.15 milligrams also recommends that DDT be handled "as a suspected occupational carcinogen? because it produced 'an increased incidence of tumors in mice in at least ll experiments. the agency says. NIOSH suggests the workplace limit be no higher than 0.5 mg./cu. meter. the lowest concentration detectable by the sampling and analysis method. The agency's ?nding differs from a recent report that determined DDT was not a carcinogen. In addition. NIOSH says it consid- ers also known by Du Ponl's tradcname Moca-- carcinogenic and recommends that concentrations be limited to 3 micro- grams/cu.meter of?air. the lowest reliably detected level. OSHA attempted to regu- late Moca in I974 as a carcinogen but the standard was deleted by an appeals court on technical grounds (CW. JUN. I. 1971;). Du l?ont. which found Moca to be a ?weak carcinogen" in dogs. had already planned to discontinue its production (CW, 5ch 6. p. 13). Cl . r- u. Next week, the chemical process indus- tries will begin operating under new rules. On Nov. 19, the main body of regulations under which the Resource Conservation and Recovery Act will be implemented becomes effective. IThe linchpin of this Phase I policy is the tracking of all hazardous wastes from ?cradle to grave??from their genera- tion to ultimate disposal at sites approved by the Environmental Protec- tion Agency. And whether it is vastly increased operating costs, a loss of cus- tomers, a shortage of licensed disposal sites, or the threat of criminal prosecu- tion, business under RCRA will never be the same. In his of?ce in Whitehall, Mich, John Yost, president of Muskegon Chemical, tries to be objective in assessing the effect RCRA will have on his firm. ?We're not negative about he says, ?but the details of the bill are making life very dif?cult for small chemical companies." Yost estimates that the burden of RCRA could increase the cost of doing business by about 10%. He says, ?That would be a signi?cant fraction of our gross pro?t.? Muskegon Chemical, which makes chemical intermediates for pharmaceuti- cals, employs just 21 people, and the demands of detailed analyses and record keeping may require the hiring of addi- tional people. Add to that potentially 64 Chemical week/November 12, 1980 5170.557 FOR I . STPCIE insertion FEE 50969:? soaring disposal costs. Muskegon new hires a licensed waste hauler to truck drums of waste to an incinerator in Utica, Mich, at a cost of about $50/drum. But Yost estimates costs could jump to $120/ drum if his company has to dispose of its wastes more fre- quently to avoid being classi?ed under RCRA as a storer of wastes. A5 a waste storer, Muskegon's annual insurance premiums could increase by $20,000 to $30,000. For the large company, the cost bur- den will not be proportionally as great. ?lt took four years for EPA to develop we?ve got months to comply? But problems abound. For example, Homer P. Appleby, manager of environ- mental and industrial affairs at Hercu- les, says his company may ?nd itself with larger quantities of hazardous wastes and fewer sites for disposal. Smaller companies that traditionally have provided a market for some of Hercules? lay-products may be forced out of business because they cannot comply with this would increase the wastes to be disposed of. ?The industry needs more disposal sites," he says. ?We will have to pay enormous sums of mon- ey to haul wastes hundreds of miles to fewer hazardous-waste landfills until more sites are put into operation." In a hurry. But there is one basic prob- lem that affects everyone: RCRA is being implemented in a hurry. ?The only real problem with RCRA is that EPA took four years to come up with these regula? tions, and we?ve got six months to com- ply," says Timothy Saylor, a research chemist involved with enviroumental affairs at Hammermill Paper, referring to the fact that published the ?nal regulations only last May. lulled industry to sleep," says Walter Huelsman of the national ac- counting ?rm, Coopers Lybrand. He points out that it took 10 years to ?put teeth into" the Clean Air Act regula- tions. ?But because of the tremendous visibility given the waste-disposal prob- lem," he asserts, has been under pressure" to move quickly under RCRA. "The dif?culty of going from a really vast era of nonregulation into one of regulation is going to present pretty sub- stantial administrative and technical problems, as well as economic prob- lems," concedes William Rhea, chief of the technical section in the solid-waste of?ce of EPA's Region VI of?ce in Dal- las. Steffen Plehn, deputy assist- ant administrator for solid waste, sums it up this way: "The sooner people get honest and get into compliance, the less exposure to our enforcement actions and to liabilities they will have Llsuggests that companies "?nd out as quickly as they can what they have to do and do it. Any efforts to avoid paper- work, capital expenditure or compliance will end up being far more costly in the long run." Tough enforcement. The Justice Dept. is already set up to prosecute RCRA vio- lators. Its newly-formed hazardous- waste section, headed by Anthony Z. Roisman 77), has ?led 51 suits to compel hazardous-waste clean- ups. And to ensure compliance with RCRA rules, Congress has made manage- ment liable under criminal, as well as civil, law for violations. Under a civil suit, companies can be liable for up to $25,000 for each day of . violation. And under recent RCRA amendments, Congress has expanded the scope of criminal actions and, in some cases, increased penalties. The key addition to an individual?s liability is the category of offense called ?knowing endangerment.? If a person responsible for handling hazardous waste knows that he places another per- son in imminent danger of death or serious injury, and if his conduct mani- fests an ?unjusti?ed and inexcusable disregard for human life,? he can be ?ned up to $250,000 or imprisoned for ?ve years. For a corporation, the ?ne can be as high as $1 million. The conference report that accompa- nies the House-Senate compromise on the RCRA amendments emphasizes that the endangerment provision is ?designed for the occasional case where the defend~ ant?s knowing conduct shows that his respect. for human life is utterly lacking, and it is merely fortuitous that his con- duct may not have caused a disaster." Even so, there is concern within the chemical industry that EPA and Justice, pushed by public fear of chemical wastes, will hit hard and early in enforc- ing RCRA. Frank B. Friedman, Atlantic Rich?eld's manager of external affairs, occupational and environmental protec- tion, warned industry executives at last month?s Chemical Manufacturers Assn. meeting in Houston of the ?increased use of criminal prosecutions.? One industry source says, ?They are going to publicly hang 50 chemical companies.? Along with the possibility of criminal indictment and ?nes under RCRA, says Coopers Lybrand's Huelsman, it is likely that the Securities and Exchange Commission will get into the act, if com- panies are registered with SEC. Previ? ously, he notes, the amount spent by these companies to control pollution was not large in relation to their overall activities. Now, he says, "the cost of compliance is high, and these companies have got to tell stockholders" about expenditures they will be forced to make under environmental laws. SEC ?will come after the guys who are not facing up to this fact," he adds. No Data. However, even though the enforcement is in place, some of the information that EPA and waste generators need is not. All hazard- ous-waste generators, haulers, storers, treat- ers and disposers were to have identi?ed themselves to EPA by Aug. 19. Plehn says the agency has received more than 60,000 noti?cations. EPA has had problems computerizing the data, how- ever, and is unable to provide informa- tion on who the ?rms are, or where they are located. The 60,000 ?gure is substantially low- er than the 100,000 ?rms EPA estimated would come under the regulations. "To some extent, we may have a compliance problem,? says Plehn, ?but we may have - Plehn: Efforts to avoid RCRA will be costly. cwnport caL?s Huelsman: EPA lulled industry to sleep. had a problem with our analysis.? Now, with Nov. 19 only a week away, an even larger problem looms. On that date, all companies are to begin tracking the movement of hazardous wastes with manifests developed by the states??ll waste disposal companies, including these ?rms which generate and intend to store hazardous wastes for more than 90 days, must have applied to EPA for ?in- terim".status as disposal sites. And all generators must send their wastes only to (treatment, storage and disposal) Most . hazardous wastes are generated in states . . . where there are the largest number. . .- of commercial f- diSposal sites 343%. 2-3595 Source: Environmental Protection Agency. 05.2% below HURT WHEN . THAT .. BUT WE RE JUS NOT GEARED FOR LOW VOLUME PRODUCTION. ships chemical waste," THEY MAYBE THEY CAN MAKE CALL FIT is the chemical company?s chemical company. If your plant is overloaded we may be able to provide extra plant capacity. It you have a specialty chemical that your operation has outgrown?but is still needed by your customers?perhaps we can make it and keep your customers happy. And here?s an idea: our unique ?Mini Plant? capabilities are available to you for small volume chemical manufacturing at remarkably reasonable costs. Tell: it Over with Hank Arkens at THE ANSUL COMPANY Marinette. Wisconsin 54143 Phone: 0'15) 735-7411. ANSUL Circle 66 on Reader Service Card 68 Chemical Week/November 12, 1980 ewnport facilities that have applied for interim status. And although it is EPA's goal, the agency cannot now tell a ?rm whether a disposal site has interim status. ?The burden is On the company that says Plehn. ?They will not be able to rely on EPA to give that assurance." As Douglas J. Lorenzen, chief of tech- nical ?services in the hazardous-wastes division of Dept. of Envi- ronmental Resources, puts it: num- ber of: companies do not know where their "wastes are going. They contract -'.'with haulers, but they don?t know if their wastes are ending up in approved sites- But corporate of?cers are liable if their wastes are not disposed of in approved sites. The problem will be: Where are the approved sites?? Meanwhile, EPA is continuing to write regulations, and under Phase II of the RCRA program the agency will guide the permit process for new facilities and for ?permanent? status for existing facili- ties. Most of these new, largely technical, standards are slated to come out this fall. But the agency is wrestling with tough issues, such as standards for con- struction Of land?lls, surface impound- ments and incinerators. State struggle. Another indication that EPA is under pressure to hurry the implementation of RCRA is the status of state programs. The same Nov. 19 date has been set as the target for states to assume the responsibility for the RCRA program. Although state governments are working to put their laws into sub- stantial agreement with the federal law, only three to ?ve states may be granted ?interim authorization? to implement their laws by that date. They are: Arkansas, Louisiana, New Jersey, New York and North Carolina. Plehn says that an additional 15 states likely will be given interim autho- rization by January, and another 20 will have reached that point by Oct. 1, 1981, the end Of the ?scal year. The states that do not have interim authorization by the first of the year will probably have a "cooperative arrangement? with EPA. Under this scheme, retains RCRA authority, but the states take over as much responsibility as possible. RCRA does Offer the states some funding to ease the transition to full regulation. Roughly $30 million has been appro- priated for this year. One big question is: How hard will the states crack down? Donald Schwaderer, senior deputy director of Ohio?s Envi- ronmental Protection Agency, says, "In our view, enforcement is critical, because industry is certainly waiting to see how Hercules! Appleby: Industry needs more waste disposal sites. N.Y.'s Nosanchuck: Computer terminals may be required. Dow's Martin: Seminars for customers play to a full house. Ferro' a Snodgrau: We help customers handle the paperwork. . serious .. state and federal gov- ernments are before they really dig into the program." Schwaderer not only sees tough enforcement as a way to cut down on illegal dumping, but he sees it as a necessary spur to investment in needed hazardous-waste-disposal sites. Invest- ing a lot of money in disposal sites is a risky business, he says, ?and the risk is decreased when the seriousness of the government in enforcing RCRA is in- creased." . . Stan Jorgensongacting chief of the solid?waste branch in Region VI of?ce in Dallas, says he is encouraging the states in his area to be very active very early. He is telling state environ- mental people to maintain ?a highly visi- ble presence" on the road. Jorgenson adds, ?We?ve even thought about issuing - bright red RCRA T-shirts with bullseyes on the bac New Jersey has a federally funded interagency hazardous waste strike force?a 30-man of?ce, combining the efforts of the state Dept. of Environ- mental Protection, the state attorney general, EPA and the US. Justice Dept. The existence of the strike force is a deterrent to illegal dumping says the state's DEP. But the effectiveness of the strike force is now being questioned, and the Oversight and Investigations Subv committee of the House Commerce Com? mittee may hold a post-election hearing on the force?s accomplishments and use of federal funds. For all states, the main enforcement tool will be in the manifest required under RCRA. States such as Texas, Loui- siana, Illinois and New Jersey have had a manifest system in operation for some time. But there is a move, among about a dozen states in the eastern part of the country and Texas to develop a uniform manifest. EPA initially proposed a uni- form manifest, but withdrew from that position at the request of industry groups. If the states, industry and the Dept. of Transportation can agree on a uniform one, says Plehn, the agen- cy will adopt it. Illinois? system may prove to be a model for a nationwide manifest. In place for a year, it uses a computer to match the waste?site operator?s report of arrivals with the waste generator?s report of shipments. ?The federal RCRA is not a real cradle?to-grave control pro- gram, it?s just an audit," says John Moore, manager of the Illinois Environ? mental Agency?s division of land pollu- tion control. ?The manifest does not come back to the agency, it goes back to the generator," he asserts. ?There is no control from the point of origin to the point of disposal." And he notes that the federal program hinges on "j ust auditing disposal sites once in a while.? Norman Nosenchuck, the director of division of solid waste for New York?s Dept. of Environmental Conservation, has looked at the Illinois program and may attempt to expand on it for his state. Concerned over the flood of paper- work his of?ce will be forced to deal with, as well as the lack of "real time" information on the flow of hazardous wastes into and out of the state, Nosen- chuck is exploring the use of computers at every stage of the hazardous-waste generation, shipping and disposal pro- cess. With such information entered on computer terminals throughout the state, he says, it would be possible to perform sophisticated analyses and 'to develop an effective ?safe corridor" or "safe harbor" to restrict shipments of hazardous waste. Nosenchuck, who also is working with the Association of State and Territorial Solid Waste Manage- ment Of?cials on a nationwide manifest, says New York of?cials ?are talking about making the installation of a com- puter terminal part of a permit require- ment? for all ?rms that handle hazard- ous wastes. Personal liability. Whether or not states turn to computers to keep track of bar.- ardous-waste disposal, the question of personal liability for compliance with the law is a troublesome one for many chemical industry managers. Mobay Chemical held a meeting for key envi- ronmental and distribution people three weeks after RCRA regulations were issued. was amazed at the questions. These guys realized very quickly whose neck will be on the line if something goes wrong," says one Mobay of?cial. The company also has held RCRA seminars for all employees. The implementation of corporate poli- cy has Hammermill Paper executives concerned. ?One big question," says Hammermill's Saylor, ?is who is going to sign those manifest forms." Under RCRA regulations, each shipment of haz? ardous waste must haye its own mani~ fest form, so that it can be traced. ?The one who should sign them is someone who actually handles the waste in the plant.? But Saylor points out that ?this is too serious a matter for someone on that level." Ferro Corp. is trying to skirt that issue by working out in advance the legal issues with whatever waste-disposal firm it is dealing with. ?Then we have an up?front legal document by which we can set out very speci?cally who is liable for what and the limits,? says Lowell E. ENTERPRISE FOB FOREIGN TRADE BUCHAREST ROMANIA is an ideal business partner, who asserts himself all over the world. The high quality of commodities as well as the prompt deli- veries are the essential characteristics of our export programme, that comprise a large scale 0! products: rubber: Butadiene Styrene Types 1500; 1502; 1508: 1517; 1?12: 1714; 1773 Polyisoprene 1?4 (:15 Types CAROMPJ 2200: 2250 Carbon black: Carbodis 50 (FEF): Furnal-T-D 300 Rebonexf?l Rebonex?) HS (HAF Flebonexa Rebonex?a IH USAF Tires: Passenger car lires cross-ply; radial and radial steel Truck tires cross-ply; radial and radial steel: Agricultural tires for land/road: tractor] trailer; Agricultural tires (standard front and rear); Industrial tires. Technical rubber items: V-belts. conveyor belts, rubber plates, hoses, carpets and gaskets. Chemical fertilizers: Ammonium nitrate fertilizer min. 33.5 0/0 Technical ammonium nitrate min. 34.5 0/0 Technical urea min. 46.3 0/0 Urea granulated fertilizer min..46 0/0 Calcium ammonium nitrate 27 10/0 Complex fertilizers: Superphosphaie granulated 16?105 0/0 P205 Concentrated superphosphate 38?42 0/0 P205 Ammonium sulphate min. 20.7 0/0 ENTERPRISE FOR FOREIGN TRADE BUCHAREST NOB-ROMANIA 202 a Splaiul lndependentei Sect. 5 Telephone: 49 50 60 49 5010 Telex: 11 489 DANAZ Fl Cable: DANAZ-R PO BOX 3915 Circle 67 on Reader Service Card November 12. 1980/Chemlcal Week or of safety and health. - thatwe?rejust providing the public with a safer world," he notes, "but it' also limiting our liability. "The big problem for the small com- pany is ?nding the time and the person- nel to meet the deadlines," says J. Richard Kiefer, corporate safety director at McCloskey Varnish, a Phila- delphia company with 100 employees. don't see how a company as small as ours can give these regulations the time they need.? . Many small chemical companies now are relying on small~generator exemption to shield them from the brunt of the act. While such ?rms still must comply with Dept. of Transportation regulations 'for shipping hazardous wastes and must still dispose of waste at state- or EPA-approved sites, they are spared much of the analysis and record- keeping mandated by RCRA if they gen- erate less than 1,000 kilograms/month of hazardous wastes. This protection may be transitory at best, according to Raymond Getty, regu- latory manager for adhesives producer H.B. Fuller. He says some states are not writing small-generator exemptions into their laws. Moreover, Michael Barclay, project officer for RCRA industrial assistance at EPA, says the agency ,is working to reduce the exemption limit to 100 kg./month of waste. And, he points out, some large disposal facilities are refusing to accept shipments of hazard- ous wastes that do not carry the EPA identi?cation numbers of large genera- tors. According to Barclay, "They don?t want to have to determine if a shipper [of hazardous wastes] is a small genera- tor or not.? A number of the larger companies have moved to help their customers, often small ?rms, to cope with RCRA. In September, Dow Chemical held semi- nars in San Francisco and Los Angeles, teaching customers how to comply with the complex regulations. The response was so overwhelming, says Jerry B. Martin, Dow?s environmental regulatory activities manager, that the company is planning to hold similar sessions in Detroit, Atlanta, Boston, Dallas and New York. In addition, Dow has distrib- uted a booklet on RCRA to about 25,000 of its customers. Ferro goes even one step further-k ?We try to assist our customers in hung dling their waste materials and handling the paperwork, says Snodgrass. Fermi even does some analytical work for 113 customers. "In many cases our custom- ers are small ?rms, and they have to remain in business if we are to remain in business. So, we make available to them our analytical laboratory. But we also go 3 out and assist in talong the samples, deciding which samples the customer; needs, and we assist the customer with the language that must be used to go 7 i permits." The path for the implementation of 1 the RCRA regulations could be smoothed to some degree if EPA establishes an}? of?ce for industry assistance, similar to 1 Toxic Substances Control Act. Plehn says such an office for RCRA is in the w,orks but? 'it will only be a switch- board?we don?t have the money to <7 assist industry 1n complying. Piehn also acknowledges that EPA has a; . not provided the regulatory interpretive memorandums (RIMS) to clarify the regulations as it has promised. But he Time IS money Use the SS short cut Inch. 88 Chemical Weak/November 12, 1980 GmetelAgonIs San Francisco General sieamsmp Corporahon. Tel (415} 772-9200 TI: FICA273705 ITT 4T0031 Loo Annalee General Sleamvhp Llc! Tel 121316881200 Tl: Portland Seanlo Johnson FOR Pl: 981; hil'HVlCE Johnson SconS?ror Johnson Scat-Isle: (North Ariadne} Tel [415) 772-9350 TI: 110112118560 General Carnival-on lei (50312281214 TI: flCAEi??i?OSlSan Honors-(111 Gsvlefal Corporal-on 1 1d lei 12061382 4-100 11: 9112113705 San Fransisco] New With A 5 CD 191(2121635-2-250 ITT 1122344 Barber Lines Inc Tel 131::- 938 9000 11: 910 2212?? Huston Hansen 8. Tamann Inc Tel (1131571 31:5 Tn 223 .1131 Honolulu Ful?l. Wald!? Tel 53:5 6934 TI: ?11 185 Vancouver, 8.6.. Canada Johnson le 16160411164 515-1 ll: 5088.15 Circle 68 on Reader Service Card CHEMICAL REGULATION REPORTER peer review of scienti?c decisions by federal agencies en- - industry plan in a report to the ational Acade- peatedly called for a peer review ds of ?sound science? on judgments The report/ ged that the scienti?c review panel be associated with the academy, but that it be provided with a set of procedures that would allow it to address qu tions more quickly than does the normal academy go?tsiittee structure. which the group called cumbersome. The proposed review panel. which would bra/established by an act of Congress. would meet emerging issues in order to "reduce delay of scienti analysis to a mini? mum.? Deliberations would be to and documentation would not be considered'unless was readily available to the public. according to wor group leader John Higginson. former director of the Int ational Agency for Research on Cancer. He noted that C, in its deliberations on carcino- gens. reviewed only ublished data. Difficult Situations becaV of low incidences. long latency periods. and/other rent biological limitations to analysis, the group' city. it said. Setting the board's agenda would be a iscretionary func- tion of its members. except that con deration of an issue would be mandatory if referred it by Congress or a regulatory agency. The board? recommendations to an agency would not be bindi but subsequent regulatory decisions on the issue the rd reviewed would be required to take into account th recommendations and to identify and explain disagree ents. The report submitted to the academy?s National Research Cou committee on institutional means for as- sessment isks to public health and should be releyd at [Qantas EFFECTIVE DATE ANNOUNCED FO LE ON 117 ANTIMICROBIAL INEFIT INGREDIENTS The rule classifying certain )rigredients used in antimicro? bial pesticides as inert ra/Lh??r than active ingredients will become effective Dec. 1 ccording to an announcement by the Environmental ection Agency (47 FR 53003). Under the requir ents of the Federal Insecticide. Fungi- . cide Act. the final rule. [which was pub- lished June 3 . could not take effect ytter a minimum for congressional review ingredients listed in the are used in antimi- i?ers. detergents, lubri- . perfuming agents. surf ants. or to perform other on-pesticidal functions (Cur nt Report. July 2, 9.1143). For further informatio contact Reto Engler. Registra- tion Division (TS-767C) ?ice of Pesticide Programs. EPA. Room 246. all Building 2. 1921 Jefferson Davis Highway. Arlingt Va. 22202; (703) 957?3661. 11-26?82 Hazardous Waste PANEL REPORT SCORES RCRA SAYS MISSOURI DIOXIN PROBLEM COULD RECUR Loopholes in the coverage of the Resource Conservation and Recovery Act allow millions of tons of hazardous waste to escape control each year. and could permit recurrence of a dioxin contamination incident in Missouri. according to a House subcommittee report. The Missouri incident. in which oil laden with dioxin was Spread over an arena, was termed a ?tragedy. compounded by the fact that the very practice which caused the initial contamination. using dioxin laced waste oil to control dust, is still permissible under present regulations." Prepared by the House Energy and Commerce Subcom- mittee on Commerce Transportation and Tourism. the ?ve- page report underscored Committee Chairman John Din- gell?s (D-Mich) remarks at a Nov. 19 subcommittee hearing on the incident. The report said ?there is as much hazardous waste that escapes pmper controls through regulatory IOOpholes. as is subject to RCRA standards.? It estimated the amount at 40 million metric tons. or 88 billion pounds per year. As a remedy, the report urged enactment of House- approved bill HR 6307 to amend and reauthorize RCRA. which would close the 100pholes (Sept. 10. p. 627). 'IIl-inforrned? Perceptions At the hearing of the Energy and Commerce Subcommit- tee on Investigations and Oversight. presided over by Din- gell. Rita M. Lavelle. EPA assistant administrator for solid waste and emergency response, said there are ?misleading. incomplete. and ill-informed? perceptions about han- dling of the Missouri dioxins and a contamination incident in Arkansas. The dioxins in Missouri are in concentrations of 100 to 1.000 parts per billion. and the agency is considering relax- ing the cleanup standard. biphenyis at con- centrations up to 133,000 parts per million are found at the other site, a residential area in Ft. Smith. Ark- Neither of the sites was on the agency?s list of emergency, life-threatening situations or on EPA's interim priority list of 160 sites requiring superfund cleanup. Lavelle said. She added. however. that the sites may be considered for long-term remedial cleanup actions under superfund at a later date. and said that testing for dioxins in Missouri would be completed and an action plan deveIOped by EPA by Jan. 15. Structural Defects Ellen Silbergeld, chief toxics scientist at the Environmen- tal Defense Fund, told the hearing EPA's inaction indicates ?a repugnant philosophy of public health protection,? but she also found structural defects in the Comprehensive Environmental Response. Compensation, and Liability Act and its regulations. She further said the National Contingency Plan lacks explicit criteria. making it ?very defective." In similar fashion. the subcommittee report said that only a small number of dioxin production processes or product uses are covered by RCRA regulations. and most dioxin wastes are not listed as hazardous under the rules. Also, most dioxin wastes do not meet one of the four characteristics of hazardous wastes under the statute ignitable, corrosive. reactive, or toxic as they are now determined, according to a subcommittee staff member. Copyright if.) 1982 by The Bureau of National Affairs. Inc. OMB-797318250050 CURRENT REPORT 951 He said EPA is working to list these dioxin wastes. but the report said that even if the dioxin wastes were listed, they still could escape coverage if they are used in recycling. All forms of hazardous waste recycling are de?ned as ?bene?- 1 uses." and as such are exempt from RCRA regulations, report said. EPA Not Afraid To Spend Lavelle told the hearing that the agency is not afraid to spend superfund dollars on emergencies, and in fact has taken 91 emergency actions since enactment of the super- fund. She acknowledged, however, that no formal risk as- sessments were made on the PC35 at the Arkansas site. "You have all these professionals telling you to take emergency action," such as CDC, the state, and EPA's regional of?ce. Rep. Mike Synar (D?Okla) said, asking why Lavelle ?went contrary to them" without a risk assessment. She said all decisions err on the side of safety and that agency of?cials with whom she consulted preferred a long-term planned removal to a temporary emergency reSponse. Synar said he doubted EPA could claim its actions were based on ?good science" with no written risk assessment. Lavelle said it was ?good science based on less than a 24? hour turnaround." Much was made of a written Lavelle statement that a child would have to eat about 150 grams of dirt laden with PCBs. or about three candy bars' worth, in order to consume a lethal dose. Lavelle admitted it a "poor choice of words.? William Hedeman, director of EPA's of?ce of emergency and remedial response. said the big problem EPA faces is where to put the dioxin?contaminated soil, because there are no dioxin disposal sites in Missouri and other states are reluctant to accept dioxin materials. Enforcement $38.5 MILLION PBB CLEAN-UP AGREEMENT UNDER SUPERFUND REACHED FOR MICHIGAN SITES A record $38.5 million voluntary settlement under the superfund program to clean up four hazardous waste sites in Michigan also will require Velsicol Chemical Co. to settle an outstanding state court action involving polybrominated bi- phenyl contamination in the state. The agreement. announced Nov. 18 by the Environmental Protection Agency. covers four sites in St. Louis, Mich.: the Gratiot County land?ll, Michigan?s tap-priority hazardous waste site; the Velsicol plant site; a storage warehouse near the plant: and an industrial waste-burning area once belong- ing to the Michigan Chemical Co. that adjoins a portion of the Edgewood golf course. Velsicol agreed to make cash payments of $13.5 million to Michigan and $500,000 to the federal government as part of the settlement. EPA said. The state will have the use of the company?s clay and deep well to complete its cleanup of the land?ll. the value of which was placed by EPA at an additional $14.5 million. The agency estimated that the company will Spend an- other $10 million to complete clean-up measures at the three remaining sites. The 3500.000 to be paid to the federal government repre? sents compensation for its expenses associated with the case. including superfund expenditures, according to Rita M. Lavelle. EPA assistant administrator for solid waste and emergency response. 11?26?82 The $13.5 million to the state is reimbursement for past, present, and future monitoring costs, compensation for ex- penses to be incurred by Michigan for remedial actions necessary at the Gratiot County land?ll, and a settlement for the state?s action against the company for polybrominat- ed biphenyl contamination problems in the state, according to Lavelle. The PBB contamination in Michigan resulted after Michi- gan Chemical Co., owned by Velsicol. mixed the ?re retar- dant chemical with cattle feed in 1973 (Current Report, May 11, 1979; Dec. 1, 1978, p. 1499). Thousands of dairy cattle had to be slaughtered as a result of the contamination and most residents of the state now have some of the substance in their blood because they ate tainted meat and dairy pro- ducts for about a year before the contamination was discovered. Michigan Chemical manufactured about 11 million pounds of the chemical between 1970 and 1976. EPA has since promulgated a rule under the Toxic Substances Control Act requiring that it be noti?ed before import or manufacture of the chemical (Chemical Regulation Reporter Reference File, 37:0091). Hazardous Waste CERTAIN WASTES TEMPORARILY EXCLUDED FROM HAZARDOUS WASTE LISTING UNDER RCRA Certain wastes generated at particular facilities have been temporarily excluded from the hazardous waste listing regulations under the Resource Conservation and Recovery Act, the Environmental Protection Agency announced Nov. 22 (47 FR 52668). EPA said its action was in reSponse to delisting petitions. RCRA allows an individual to petition for exclusion from the hazardous waste list on a site-Speci?c basis. To qualify for delisting, the agency said the waste gener- ated by a particular facility must not meet any of the criteria under which it was listed as hazardous. An excluded waste still may be hazardous if it exhibits any of the characteristics of a hazardous waste. the agency continued. and generators ?remain obligated to make this determination." Matthew Straus, manager of Hazardous Waste De?nition Program, told BNA Nov. 23 this was the sixth temporary exclusions list published by the agency. Straus said 412 such petitions have been ?led with the agency, and that action has been taken on about 150 of them so far. The most recent listing was announced Dec. 16, 1981 (Current Report, Jan. 2, p. 1029). Comments on the exclusions should be submitted by Jan. 21, 1983, to the Docket Clerk, O??ice of Solid Waste, EPA, 401 St. S.W., Washington, DC. 20460. Pesticides EPA PUBLISHES TOLERANCE AMENDMENTS, PROPOSALS. REGISTRATION APPLICATION The Environmental Protection Agency Nov. 17 through 24 published four tolerance amendments, proposed tolerances for and magnesium phosphide, granted three tempo- rary tolerances, and approved an application to register a product involving a changed use pattern. Tolerance Amendments A tolerance was established for ethOprop on mushrooms at 002 parts per million (47 FR 53004). For further informa- Chemical Regulation Reporter OMB-7973182150050 ~hem?calweek Editor-in-Chiet John B. Campbell Managing Editor Donald R. Cannon Executive P. Burke Senior Editors Claudia H. Deutsch Paul L. Edwards Herbert C. Short Homer Starr Assistant Managing Editors Edwards John W. Price. Jr. Art DirectorFtobert P. McAuley Assistant Art Director T. Walsh Associate Brooks [Technology] Albert H. Kislin (International) John M. Winton (Energy/Feedstocks} \lews Editor Joseph F. Dunphy Department Editors Companiesw David Gibson Environment Lee Harrison Finance/Economics Gregory W. Miller Management William D. Kosrnan G. Dumas Markets John Rivoire People Richard B. Roberts Stall Editors Imelda Fl. Bmce Richard J. Zanetti Assistant D. Bluestone Fredric Dannen Deborah W. Hairston Editorial ProductiOn Manager Muller Editorial Production Assistant Patricia Leonard Business Nigra 3w Newswire Manager Joseph F. Dunphy SERVICES EconomicsEnc B. Herr World R. Johnson. director Chicago. Jet! Flyser. Cleveland, Arthur Zimmer- man; Detroit. David Whiteside; Houston. Robert E. Lee: Los Angeles. Barbara Lamb: San Francisco. Margaret Ralston Drossel; Southeast. James Bran- scorne; Washington. Robert E. Farrell. Bonn. Robert Ingersoll; Brussels. James Smith: London. James Trotter. Madrid. Jules Stewart; Milan. Lois Bolton; Moscow. Alex Beam; Paris. John Sao Paulo. Frank Taylor: Stock- holm. Robert Skola; Tokyo. Robert Nell; Zurich. Laura Pilarski BUSINESS Director of Business James Methven Billings/Statistics Manager Astrid Chahmirian Director of Production M. Retzlafi Asst. Production Kroll Director of Research Bertha Chase Marketing Deborah Smikle Director of Circulation Paul W. Erb Manager. Buyers? Guide . Rimondi Director of Servrce Raymond F. Framed Services AssocrateSyIvra M. Larkin Admin. Asst. to A. Fells M. Mager EPA passes a test on RCRA . . . Just a little more than a year and a half ago, the main body of regulations under the Resource Conservation and Recov- ery Act went into effect. As our cover story points out the Environmen- tal Protection Agency has not set any course records in implementing the act. Still, we think that the agency is doing a creditable job. RCRA, the most sweeping legislation ever enacted on the disposal of hazard- ous waste, requires ?cradle-to?grave" tracking of wastes from their genera- tion to their disposal in an proved dump site. Implementing the law presents some staggering prob- lems. First, the EPA under Anne M. Gorsuch had to unravel some inherited regulations that, we think, were hastily drawn and poorly conceived. Then, it had to try to pin down such crucial de?- nitions as ?hazardous" and ?solid waste." Both EPA and industry have had to cope with a shortage of dump sites. And the states. which are autho? rized to implement their own versions of RCRA, lack the money and manpow- er?at a time when federal support funds are being cut back. So EPA has moved slowly, and some of the wolves in Congress and among the enviroumentalists are starting to howl. It's true that EPA's performance has not been beyond reproach. It has consistently missed deadlines for key regulations. The ones that do issue come out piecemeal and are consequent- ly hard to track and sometimes harder to understand. But merely to fault EPA is to ignore the progress that has been made. Indus- try has been forced to take a searching look at its waste-generation and wastt.L disposal practices. The whole subject has been brought forcefully to the at.- tention of management. Moreover, some of the knotty problems are being straightened out. At one time, there were 27 serious points of contention be- tween EPA and industry. These have been narrowed to ?ve, and those ?ve are the subject of negotiations now. That sort of give-and-take is essen- tial. If the parties cannot work out their differences before regulations are is- sued, they will end up in court. And litigation always runs a distant second to negotiation. . . . but flunks one on P033 A rule covering the incidental manu- facture of biphenyls (PCBS) is being proposed by the Envi- ronmental Protection Agency. The un- scienti?c and discriminatory proposal points up the need for more informed opinion on the hazards of PCBs. The agency is under a court order to justify the cut-off point, 50 ppm, that it had previously established. Instead of providing justi?cation, EPA is trying to beg the issue. Its proposal would apply to any quanti?able amounts of PC-Bs found through use of a highly sophisti- cated analytical system (C W, June 2, p. But by so doing it. would estab- lish a limit for PCBs that has no more scienti?c validity than the 50vppm level. Details of the proposal were not available by the middle of last week. But the required analysis is expected to call for an electron-impact mass spec- trometer in conjunction with capillary column-gas chromatography. That's go- ing to entail an enormous expense. And even the top labs in the country have had trouble using the system to quanti- fy with any precision the presence of PCBs in complex mixtures, such as those in which incidentally generated PCBs would be found. The proposal discriminates against the chemical industry. A study by the Chemical Manufacturers Assn. shows that perhaps 660 lb/ year of incidentally generated PCBs would ?nd its way into intermediates or would be locked into commercial products. That?s a drop in the bucket when compared with the amount that will escape from existing electrical installations. EPA has arrived at a poor answer for a touchy question. Our feeling is that the cut-elf point of 50 provides an ample safety margin. A number of epi- demiological and animal studies Show that even high exposures to PCBs pose no threat to life. But EPA ?nds them inconclusive. The reasonable answer would be an international symposium to look at the studies and either reach conlusions on the toxicity of P033 or recommend studies that would be need? ed to reach such conclusions. June 9. 1982/Chemicel Week 3 1' - ?row?WW. OUR NEW NAME REFLEOTS OUR DYNAMIC GROWTH AND OWERSIFIOATION (I L: -?l-pnasrics mc. We started in business only a decade ago in Linden. New Jersey with our first chlor?alkali plant. Now our chemical and plastics plants and distribution facilities span the nation. Recently we acquired properties from international Minerals and Chemical Corporation which now makes us a leading merchant-producer of caustic potash and related potassium products. and significantly expands our production capabilities and marketing area for chlor'alkali products. We've taken ?Linden" out of our name, but the same commitment to service and reliability that has made our remarkable growth possible remains. 4 Chemical Week/June 9. 1982 JUST ?5 LOP KOH (Liquid) KOH (Flake) KOH (Walnut) Potassium Carbonate Chlorine Caustic Soda Chloropicrin HCI Muriatic Acid Sodium Hypochlorite Methyl Chloride Methylene Chloride Chloroform Carbon Tetrachloride PVC Pipe and Fittings IE CHEMICALS 8 PLASTICS INC. F?areLan Plus it - Harman Center Edison, 08837 (201) 225-4840 ?Getling BORE under control The Environmental Protection Agency says it plans to issue this month a nunr ber of technical regulations and stan- dards on hazardous waste. These will form part of a program the agency says will bring its administration of the Re- source Conservation and Recovery Act under control. But industry. state governments and environmental- ists have adopted a wait-and-see atti- tude. Although the EPA has issued nu- merous regulations since Nov. 17, 1980, when the act took effect. some of the moshimportant are still hanging ?re, and the act?s ?nal shape is in doubt. Moreover, that doubt is now being compounded with confusion. Industry and environmentalists alike, unhappy with much of what they already see. Despite many regulations, the shape of policies remain in doubt have challenged numerous regulations and are involved with EPA in negotiations over the way those regula- tions should ultimately read. The states. which administer RCRA, are ?nding their efforts hobbled because promised federal aid has not materialized. Into the fray. With an election coming up. Congress is likely to get into the fray?particularly since HERA must be reauthorized by Sept. 30. the end of the ?scal year. The House Energy and Commerce Committee has passed amendments that would tighten RCRA and force the EPA to implement the en- tire act on a speci?ed timetable. Top EPA officials say that their agen- cy has adjusted to the change from the Carter to the Reagan Administration and that they are making progress in implementing the act. They have gone numerous times to Capitol Hill, armed with statistics and schedules that show, from the agency's point of view. a clear stream of regulatory progress. These officials also say that most of the tech- nical standards are already in effect, and that those that are not soon will be?including de?nitions of hazardous waste. and standards for the design and 36 Chemical Week/June 9. 1982 operation of hazardous-waste landfills. The chemical industry, for its part, is doing its best to cope with the confu- sion. Companies are generally comply- ing with regulations already issued. while awaiting the outcome of negotia- tions with EPA on 27 of the more techni- cal issues {boax p. .18} in what has be- come known as Shell Oil vs. EPA. The industry. hoping that the regulations will be issued soon in their final form, is almost unanimous in its support of EPA. The Chemical Manufacturers Assn. maintains that the agency ?has been doing a responsible and conscien- tious job addressing the issues." calling the pace of development. "necessarily slow." The delays, says the association, result from ?the difficulty and complex- ity of achieving the goals prescribed by the act. and not from lack of statutory authority or from lack of diligence on EPA's part." Money shortage. The opinions of state environmental of?cials vary widely both being implemented by EPA. But most agree that there is not enough money avail- able to fund their programs for enforce- ment and issuing permits. Says Norman H. Nosenchuck, director of solid waste for New York's Dept. of Environmental Conservation: ?States are now faced with the grim prospect of attempting to carry out urgently needed. federally mandated programs with (.lecreasing federal financial support." While allows states to obtain ?authorization? to implement their own versions of the act. more and more states are coming to the conclusion that. in the face of federal budget cut- backs, they may not have the money or manpower to do so. Money is not. the only problem for the state agencies, however. Constantly changing RCRA regulations and delays in releasing some of the most important rules have brought additional dif?culties. and some states are about to cease. trying to en- force a move that would force EPA to implement the act by itself. Environmental groups. on the other hand, see all this delay as an attempt by EPA to render the act impotent. ?Since the change of administrations in 1981." says Khristine L. Hall. attorney for the Environmental Defense Fund. ?it has become regrettatdy clear we _are no longer moving forward in protecting health and the environment from mis- management of hazardous waste." But there are. some who feel the act is having a positive effect. is working surprisingly well." says James A. Rogers. formerly chief attorney for EPA's air, water and solid waste sec- tion. and now an attorney with Skad- den, Arps, Slate, Meagher 10m in Washington. He bases his case on the simple assertion that "no one is going to court." Rather. says Rogers, people are willing to negotiate their differ- ences. He feels industry and environ- mentalists have, over the past 10 years. learned valuable lessons from the com- plexities of the Clean Air Act and the Gorsuch feels political pressures. ?1 an Agency II. I June 29, Tuesday -. I am. Investing in University Research: Wh tit I impact or University Research on '0 0 Corporate Competition Charles A Sanders Science Administration I Pr - . eceding Speakers E. R. Squtbb Sons. Inc. I Former General . $2004 :30 pm. Luncheon Address: Training and Massachusetts General Hospital I Use of Manpower Direct or Indirect . I William Blrenbaum Corporate Funding? President Antioch Coil E. C. Galloway eg Executive Woe President? I 1:30-2:30 pm. Patenting Technical wV - Staufter Chemical Co. mo ulneratble its Board Member. Council for I orpora Ion. Chemical Research I A Richard I General Patent Counsel 10:00-10:30 a.m. Coffee Intermission I and Assistant Secretary Eli Lilly and Company Licensing. Contracts?and How Vulnerable is the Celanese/Yale Michael K. Kirk Joseph 5. Warner I Assistant Commissioner Director of Grant Contract for External Affairs Adm?msf?m'on U.S. Patent and Trademark Ollice Yale University I U.S. Department of Commerce . . 10:30 42-00 pm. Making the Most or the I 2'30?3'00 Corporate Academic Tie The Search for Know-How Erich Bloch Richard A Cowley vice President, Research I International Business I Rain Hm Group, Inc. Machines Corporation 3:004:00 pm. Technology Protectionism Chairman. Semiconductor I Roundtable Industry Association Preceding Speakers $625 dtemiodweek it I To attend the Chemical Week Executive Conierence on 8: D: The U.S. Advantage" June 23-29, 1982, at McGraw-Hrli World Headquarters. 2nd Floor Mezzanine. 1221 Avenue of the Americas. New York. New York, fill in the coupon or write on your company letterhead to. The MoGraw-Hilt Conterence Group Please check appropriate box: 1221 Avenue at the Americas I Payment enclosed (Make check payable to 3008 36?? The McGraw-Hrll Conference Gr0up) New York. New York 10020 Please bill me directly Far information. call: 212/997-4931 Please bill company (Payment clue prior to conierence) Please or Type (coupon may De duplicated and attached tor additional registrants) Name Title Telephone i Company Address City State Zip Registrant's Signature Hob! Reservations: The New York Hrtton {21215867000}. is holding a block of rooms up to three weeks prior to the conference For reservations. contact the hotel directly. Please be sure to identity the titie and dates of the conference t0r preterentiat treatment. Cancellation Liability: In the event of cancellation of the conference for any reason, McGraw-Hili's liability is limited to the return at the registration tee. Cancellation Policy: All cancellations must be received in writing. Those postmarked June to. 1982. or atter be subiect to a service charge at $150. Registrants who tail to attend and do not cancel prior to the conterence are liable tor the entire registration tee. You may, it you wrsh. send a substitute. June 9. 1982/Chemical Week 35 Florio wants to tighten the screws. Clean Water Act. "They have found that you can litigate for years and, be- cause the courts generally don?t rule on arcane technical matters. you wind up negotiating anyway.? Through negotiation. So far, the chemi- cal industry seems to agree. ?We have made progress through negotiations be- tween industry and government," says R.H. Dreith of Shell Oil?s environmen- tal affairs department. Shell is one of 38 petitioners?including Dow Chemical. the Chemical Manufacturers Assn. and the Environmental Defense Fund?that are negotiating with EPA. The Shell Oil case developed in response to standards, promulgated May 19. 1980. that cover operations that produce and transport hazardous waste. The indus- trial petitioners in the Shell negotiations have identi?ed 24 points in those regu- lations that they want speci?cally ad- dressed by EPA. while EDF has named three issues it wants clari?ed. ?At one time there were 27 recog? nized serious points of contention." says Dreith. ?That has been trimmed to ?ve, and negotiations are under way on those." The act is very comprehensive in its approach to hazardous wastes, he says. ?but there has been a big problem lationpassed in_1980 reinforced ageiicy dealing with the language of the laws? in some cases we?ve had to put out our own interpretations of just what the law is supposed to do and not do.? The Chemical Manufacturers Assn. has taken a conciliatory view of the way EPA has been implementing RCRA. Philip A. Palmer. head of (fMA?s RCRA Regulatory Task Group and Du Pont?s top hazardous waste consultant. says that when the act was passed few states had regulations for hazardous waste. and that the early state laws were not as comprehensive as those EPA must now adopt under RCRA. The process at the federal level. says Palmer, began without good models, and the agency was faced with the diffi- cult task of de?ning such fundamental terms as ?hazardous" and ?solid waste." Further. he says: ?It is clear that the initial statutory deadlines for promulgation of RCRA regulations were unrealistic." But, he adds. ?the EPA has made commendable progress. especially during the last three years." ?Playing catch-up.? Despite this record of progress, says Rita Lavelle, new assistant administrator for hazard- ous waste, it is still easy to attack the agency. "We're playing catch-up in the RCRA arena, so it would appear that we're disorganized and disjointed.? She blames ?uphill battle? on the Car- ter Administration which. she says, waited until the end of its four years to issue several ?ill?conceived" hazardous waste rules. ?The regulations promul- gated at the end of 1980 were thrown out as a Band-aid to the public to show that something had been done with says Lavelle. "But. boy. talk about a midnight dump. Those regula- tions contained a lot of 'thou-shalt?not? rhetoric. but very little on what one can do to manage hazardous waste." The regulations expected from EPA this month include long-awaited stan- dards for new and existing land?ll sites and incinerators and rules for issuing permits for new hazardous-waste facili- ties and expansion of those already ex- isting. De?nitions of what constitutes solid waste are to be issued about the same time. Lavelle says these rules will be a great improvement on those issued under the Carter Administration. Less optimistic. The House Energy and Commerce Committee. however. is not so optimistic. While it is considering leg- islation to reauthorize the act. the com- mittee would like to tighten the regula- tory screws 3. little. In April, at hearings of the House subcommittee on Commerce. Transportation and Tour- ism, chaired by Representative James J. tainers for short-term storage. envron ent Florio witnesses from envi- ronmental groups, state governments, universities and some industries made clear their concern about the way EPA is implementing the act?and about some of its loopholes. On May 11, Florio?s subcommittee recommended a number of amend- ments. most of which have been passed by the full Energy and Commerce Com- mittee. These would: reduce to 100 from 1.000 kilograms/month the amount of waste a ?small generator" would be al- lowed to produce before being required to comply with RCRA regulations; tight- en regulations governing disposal of hazardous liquids in land?lls; regulate industrial boilers that burn fuel contain- ing hazardous wastes: limit the time al- lowed EPA to issue land?ll-site permits to four years; and create a national groundwater commission to assess the relationship between groundwater con- tamination and hazardous wastes. Election Some members of the chemical industry see Florio's hear- ings and subcommittee amendments as so much election-year politicking. ?What data. what problems warranted States applying the act are hobbled by a lack of Washington funding these amendments?" one industry lob- byist asks, contending that no one pre- sented the subcommittee hearing with data or facts that would support these amendments. He believes that the amendments may only cause further de- lay in the act?s implementation. For small chemical companies, though. the Florio subcommittee?s pack~ age could result in more than just de- lays. ?The small-generator exemption could pose a lot of problems for our companies," says Ronald A. Lang. exec- utive director of the Organic Chemical Manufacturers Assn. He warns that almost every chemical com- pany. no matter how small. would fall under the proposed RCRA amendment, with all the cost that would entail. ?This means we now have to pay a lot of attention to [Florios?s] RCRA reauthori- zation bill,? says Lang. Some states, moving ahead with their own RCRA regulations. have already taken action against the small genera- tor of hazardous waste because they fear future dumpsite problems. Califor- nia, for instance, allows no exemptions at all; Louisiana has acted in a similar way. ?Yes, we are very concerned June 9. 1982/Chemicai Week 3? ing negotiations. June 9, 1982/Chemical Wedt 39 envronment envron en list, there are materials not on that list that might deserve special treatment too. ?Many people believe that if a sub- stance is not on the RCRA hazardous- waste list they have no legal exposure," says a Washington attorney. ?But most manufacturers realize. when they are dealing with substances that are at least as toxic as the listed wastes, they should treat them as such to avoid civil lawsuits.? While it is virtually impossible to as- sess the amount of waste going into land?lls unlabeled or improperly la- beled, perhaps the biggest unknown quantity in the whole RCRA question is the volume of hazardous waste burned in industrial boilers. Because this burned waste is being put to a ?bene?- cial use," it is not covered by RCRA EPA wants to negotiate but is prepared to take companies to court if need be regulation. Florio?s subcommittee would change that, and in this he has the sup- port of the Hazardous Waste Treatment Council, a group of waste-treatment ?rms. ?The scope of this is truly enor- mous," says Richard M. Hall, attorney for the group. ?Some EPA of?cials have estimated that-tens of thousands of boilers may be burning hazardous waste." The hazardous-waste group also sees the possibility of problems in disposing of residue from industrial boilers burning hazardous waste. The group says that such residue is also hazardous and should be treated accord- ingly. Anguished cries. While EPA has caused cries of anguish from all quarters for the stutter?step way it has issued RCRA regulations, it is the agency?s capability and Willingness to enforce those regula- tions that has caused the most heated debate on Capitol Hill. And as critical elections near, the enforcement issue could cause the Administratiou some of its most serious political problems. Flo~ rio says simply that lately en- forcement effort has been ?virtually nonexistent," and points out that fr0m March to December 1980, during the Carter Administration. EPA referred 43 RCRA enforcement cases to the Justice Dept. for prosecution. Throughout 1981, the ?rst year of the Reagan Adminis- tration, EPA referred no more than ?ve such cases, says Florio, adding that no cases were sent to Justice during the ?rst three months of 1982. At EPA, however, they see it differ- 40 Chemical Week/June 9, 1982 ently. ?We feel we are meeting the congressional mandates of says Rita Lavelle of the agency's hazardous waste department. "And we feel we are meeting them within the framework of relevant objec- tives put forth by President Reagan." Despite what such critics as Florio say, Lavelle claims the Administration?s policies on hazardous waste en- forcement are working out well. She stresses EPA support for voluntary cleanup agree- ments with companies. as op- posed to litigation. ?In? dustry has the talent and expertise to protect the envi- ronment. We need their help. Our best success stories are those in which we have cooper- ated with industry," says La- velle. Nonetheless, the absence of a "body count" on the JUStice Dept. court docket is weighing heavily on EPA. Gorsuch has admitted as much, and the agency may be out to improve its record. ?There's going to be a line drawn," says Robert M. Perry, new associate administrator for legal and enforcement counsel. ?It will be clear that if you go beyond the line. there?s going to be a court case.? Lack of The problem over the past year, Perry says, has been in a lack of communication be- tween headquarters and regional of?ces over how to negotiate with companies. Perry insists that the Reagan Adminis- tration's approach ?does not mean we?re going to sit and negotiate all day." He says that some regional Ofl?l- cials misunderstood the intent of the agency?s enforcement policy and stopped preparing for litigation when entering negotiations with a company. That practice has ended, Perry says. ?You've got to have the possibility of litigation to have meaningful negotia- tions. We want to make that clear to the regulated community. We are ready to go to court if necessary." Perry, however, says that to carry out this rede?ned policy the agency will by the fall have beefed up its criminal investigation staff to 20 investigators and four lawyers from the present five investigators and two lawyers. Field technicians and some lawyers have been sent to the Federal Law Enforcement Training Center near Brunswick, to learn basic criminaldnvestigation tech- niques. Further, the agency has signed nosing it ~edibil~ Nosenchuck of New York: States may quit a memorandum of agreement with the Federal Bureau of Investigation under which the bureau will handle up to 30 environmental investigations a year. "We're really committed to the enforce- ment program," Perry says. ?Believe me. if we can?t get voluntary compli- ance, we'll move in with every tool We've got." 'More with less.? And EPA may have to do just that, according to Norman No- senchuck of New York State's Environ- mental Conservation Dept. ?The states are not effectively picking up where the federal enforcement effort leaves off," says Nosenchuck, who is also president of the Assn. of State and Territorial Solid Waste Management Officials. He says that many states organized their initial RCRA enforcement efforts while counting on 75% federal funding. "But that funding never materialized," says Nosenchuck, ?and states are being asked to do more with less." And he cites an EPA proposal for a 16'7"? cut in state funding for ?scal 1983. Nosenchuck says bluntly that New York and nine other states are consider- ing withdrawing from the federal RCRA program. ?It?s a good law,? he says. ?but it needs to be funded properly." That funding, he adds, may have to come in the form of new state fees and taxes on the chemical industry. RCRA decrees insurance for hazardous wastes After nearly lri months of forth haggling and policy reversals. Re- source Conservation and Recovery Act regulations that require envirtmmental liabilitypinsurance will at last go into effect. From July 15. the ei?i'ective date of?the regulations. 10.000 owners and operators of hazardous-waste facilities in the including many chemical companies. must carry $1 million in in- surance against a sudden accident. such as a spill or explosion?to a total 01' at least $2 million/ year. Coverage for each individual ?nonsudden" incident. such as leakage from a dumpsite. must be at least $3 million?to a total of at least. $6 million/year. Snodgrass: His company found only two carriers. While insurance for sudden accidents has been available under the general liability policies held by most industrial companies, the RCRA requirement that companies carry coverage for nonsud- den occurrences is forcing the insurance industry to develop an entirely new kind of coverage: environmental-impairment insurance. Work on developing these policies began at least 18 months ago, but changes of mind at the Environ- mental Protection Agency, which will enforce the RCRA requirement. and at the Of?ce of Management and Budget, 44 Chemical 30. 1982 which reviews any rules proposed by the agency. have kept the insurance in- dustry in a state of uncertainty. It is still not clear what kind of. and how much, environmental-imi'iairment insurance will be on the market when it is needed. Many insurance companies are staying out of the market until some experience has been gained with setting the premiums and paying out for losses. And thOse companies that already carry substantial amounts of general liability business are being cau~ tious, responding only when a present customer asks for coverage. EPA has foreseen problems. ?Because of the limited immediate availability of nonsudden coverage from in- surance companies," says John H. Skinner. of EPA's solid- waste the nonsudden re- quirement will be ?phased in" over a three'year period. Com- panies with annual business volumes of $10 million or more must have nonsudden liability coverage in place by January 1983; companies doing between $5 million and $10 million worth of business have until January 1984; and companies doing less than $5 million have until January 1985. Hard to find. But even with the phase-in. companies are ?nding it troublesome to comply with the regulations because the in- surance is di?icult to obtain. ?We found there are two in- surance companies willing to write that type of policy,? says Lowell E. Snodgrass, director of safety and health for Ferro (Cleveland). "We're talking about year in premi~ urns for $10 million in coverage." This is not a make-or?break amount for Ferro, says Snodgrass. "but if you have a small company that is in one of those businesses which creates hazard- ous wastes that are extremely ditIicult to get rid of. or has its own treatment, storage. and disposal facilities. it could be the difference between pro?tability and nonprolitability." An executive with one small New Jer- sey chemical company is facing just such a dilemma. "We've been looking for environmentaI-impairment coverage since the beginning of 1982." he says. "and we cannot locate a source." Price. he says. is the problem. can only describe the numbers quoted us as un- reasonable," he adds. ?We know it"s a problem, but right now we don?t have a solution." insurance companies see things dif- ferently. They say that carriers are vy- ing for business and prices are de- pressed. And as more insurers get into the envirimmental-impairment. business, says one. insurance company executive who chooses anonymity. the competition will increase and prices are likely to come down further. That. he says, could leave some carriers in a bad position if major losses occur. "It might turn out that we won't be able to write environ- mental-iinpairment insurance," he warns. lot will depend on what we ?nd out there." Testing the water. The ?rst to offer insurance was Shand Mo 'ahan. a subsidiary of the large insurance broker. Alexander Al- exander. And at least seven other do. mestic insurance lirms have tested the same water: American International Group, Stewart Smith. Swett Craw- ford Management, Alexander Howden Coverage for environmental impairment?from nonsudden incidents?is in short supply Services. Travelers. Aetna. and U. S. In- surance. Now. says. John W. Buckley, senior vice-president of Alexander How- den Services, it is the buyers of environ- mental-impairment insurance who are holding back. "It is only sudden and accidental insurance that goes into ef- fect in July, and most ?rms already have that. so we've seen no ?ood of appli ations." He expects applications for environmental-impairment insurance to pick up later in the year as the Janu- ary deadline approaches and companies are refused such policies by insurance tarriers that currently serve them. The largest chemical companies, how- ever. having made their case with EPA that they should be allowed to self-in- sure. will remain above the fray. Under the new regulations. companies can be self-insured if they pass a ?nancial test that requires them to document that their net working 'apital is ?six times the amount of coverage" they would be required to have and that either their net worth is at least 810 million or their bond rating is in the ?rst four catego- ries listed by Standard Poor?s or Moody's. marlets newsle Demand for titanlum dioxide is sluggish Production of titanium?dioxide pigment is increasing slowly, after hitting a low of 43,750 tons in January. But the performance this spring, compared with that of a year ago, has not been encouraging. The produc- tion level in 1981 bottomed at about 58,300 tons in January and rose steadily to about 70,200 tons in May. This year, February?s output topped January?s by about 14,000 tons, but production in March dropped back to 56,500 tons. Total output for the ?rst quarter was 158,100 tons, down from 181,900 tons a year earlier. Business will have to pick up soon if this year?s total is to come anywhere near last year?s 750,100 tons. A pick-up is unlikely, however, given that the big markets for titanium dioxide?paint, pa- per and plastics?are lagging. A bullish forecast for titanium metal James L. Daniell, president of RMI, predicts a signi?? cant increase in demand for titanium metal next year and a doubling of titanium demand during the next decade. Cost reductions, which are expected to be as high as 50% in constant dollars, will play a large part in the market?s expansion, he says, and most of them can be achieved by applying current technology. Dan- iell?s interest in cost reduction has been spurred by competition from low-cost imports, primarily Japa- nese. He comments, ?Our research has been funded to pursue new technologies that will reduce costs and beat the Japanese and other low-cost importers at their own game.? The company recently cut its titani- um-sponge price by 27%, to $5.55/lb, in response to increasing overseas competition in a market that has been hurt by sluggishness in the demand for com- mercial aircraft (CW, May 12, p. 5.9). RMI is owned jointly by U. S. Steel and National Distillers Chemi? cal. The two companies are considering selling to a third party (CW, June 16', p. Per-caplta use of will rlse 68% The world?s per-capita consumption of plastics will rise 68% (3.5%Iyear) by 1995, says Predicasts, (Cleve- land, 0.). The consulting organization expects per- capita consumption of plastics in 1995 to hit 22.5 kilo- grams, compared with 13.4 kg in 1980. World population, the ?rm says, will grow 5.7 billion?from 4.38 billion in 1980. The world?s total consumption of plastics is projected to rise to 131 million metric tons in 1995, compared with 61 million m.t. in 1980. High?density polyethylene and polypro- pylene are expected to post the highest growth? year and respectively. Low-density polyethylene, however, will remain the largest-vol- ume resin, according to Predicasts. The 1995 polyeth- ylene volume is projected at 26 million compared with 22.4 million m.t. for polyvinyl chloride, 15.6 mil- lion m.t.for HDPE and 13.5 million m.t. for PP. The carpet-fiber business is picking up It looks as though demand for nylon carpet ?ber has turned the corner. Robert Tra?et, home furnishings vice-president and general manager for Allied Eibers Plastics, says that current sales are running a; about 70% of capacity, compared with a low of 54% 0 capacity in December 1981. Producers? inventories, moreover, dropped by about 8 million lb in May and are now 35% below their peak, set in October 1981, of 154 million 1b. Current inventories are about equiva- lent to a four-week supply, a healthy level by indus- try standards. But Tra?et says he is waiting for retail~carpet sales to rise before he becomes bullish about the outlook for carpet ?ber. Anticipating a turnaround, Allied, like other makers of carpet ?ber. has been developing new products. Allied is introduc- ing a total of 212 new products this summer, includ- ing several aimed speci?cally at the contract carpet market, which usually sets the pace for innovations and improvements in carpet design and usefulness. Fertilizer makers make up some lost ground The fertilizer movement has picked up in the Mid- west, closing some of the year-to?year gap that devel? oped earlier in the ?scal year. The 1981-1982 fertilizer year comes to a welcome end on June 30, and market- ers are already looking ahead to 1982-1983. The 1981- 1982 domestic consumption was probably about 48 million tons, down from 53.3 million tons in 1980?1981. Reports from marketers indicate that they had heavy domestic movement in both May and June, although recent rains have hampered application of fertilizer in some areas. For marketers, one positive note is that the recent pickup in business has combined with plant shutdowns to cut their inventories; and a recent increase in overseas orders has added an even more optimistic tone to the market. Badische outs organics prices Badische has cut its prices for normal butanol, isobu- tanol, and phthalic Normal butane] is down 3.5c/ lb, to 33.5c/ 1b; isobutanol is down 3501/ lb to 28.5c/ lb; and is down 5c/lb, to 40? lb. The list price of molten phthalic was cut 9c/ lb, to a new level of 33c/ lb, and Badische is granting a temporary allowance of 1c/ lb, making the effective price 32c/1b. The new effective price for ?ake phthalic is 452/ lb. June 30. 1982/Chemical Week 43 E885 Noriega I-aperspectrive view What are they? Toxic chemicals. How many are there? l29. Complying with a l976 court settlement, the US. Environment Protection Agency is spending about $60 million to obtain the necessary data for forthcoming regulations that are the beginning ofa better way to monitor industrial waster-t 'ater discharges. Next month ?s authors present a cost-effective method to analyze for these pollutants Larry ll. Keith Radian Corporation Austin, Texas 78766 William A. Telliard US. EPA Washington. D. . 20460 One objective of this article is to relate the historical origins of Pribrity Pollutants and the develop- ment of the ?Priority Pollutant Pro- tocol." Most people are unaware of the difficulties involved in providing methods for the necessary analytical support for these pollutants. A second objective is to summarize the status of the current analytical procedures in their present and still-developing forms. A June 7, I978, court settlement involving the EPA and several envi- ronmentally concerned plaintiffs (Natural Resources Defense Council. lnc.; Environmental Defense Fund, lnc.; Businessmen for the Public ln- lne.: National Audubon Soci- ety, Inc; and Citizens for a Better Environment) has commonly become known as the Consent Decree." These groups brought suits against the . EPA for failing to implement portions ofthc Federal Water Pollution Control Act (P.L. 92-500). One result of this suit required to publish a list of toxic pollutants for which technol- ogy-based ef?uent limitations and guidelines would be required (53d? T. February I978. lS-i). The Consent Decree dictates that. . . the (EPA) Administrator shall develop and promulgate regulations which shall establish and require achievement at the earliest possible i . ?lv umronmental Science 5 Technology TABLE 1 Point-source categories'3 Date tor promulgatlon Category of regulation Timber products processing 12/79 Steam electric power plants 12/79 Leather tanning and finishing 8/79 Iron and steel manufacturing 5/80 Petroleum refining 10/79 Inorganic chemicals manufacturing 4/80 Textile mills 12/79 Organic chemicals manufacturing 8/80 Nonferrous metals manufacturing 3/80 Paving and roofing materials 1/80 Paint and ink formulation and printing Paint and ink 4/80 Printing and publishing 8/80 Soap and detergent manufacturing 1/81 Auto and other laundrics 7/80 Plastic and materials 8/80 manufacturing Pulp and paperboard mills and converted 8/80 paper products Rubber processing 1/80 Miscellaneous chemicals Adhesives 8/80 Gum and wood chemicals 3/80 Pesticides 10/80 Pharmaceuticals 7/80 Explosives manufacturing 7/80 Machinery and mechanical products manufacturing Aluminum forming 10/ 80 Battery manutacturing 10/80 Coil coating . 3/80 Copper forming 11/80 Foundries 5/80 Plastics processing 5/ 81 Procelain onatnel 5/60 Mechanical products 3/81 Electrical and electronic components 10/80 Electroplating 10/80 Ore mining and dressing 7/80 Coal mining 6/80 The Consent Decree requires standards for 21 industrial categories. lesrr new rja'es lor nromulgahon are awaiting approval by the U.S. District Cour}. 1979 American Chemical Society no case later than June 30. effluent limitations and incs for classes and categories of mi sources which shall require ap- plication of the best available tech- nology (BAT) economically achiev? able for such category or class . . The Consent Decree also requires new source performance standards and pretreatment standards for 21 indus- trial categorics (Table in addition, EPA has decided to review public owned treatment works (POTWS) as a separate category. The original Consent Decree con- tained a strict scheduling ofcontracts to be issued and dates for the required regulations to be promulgated (Table The schedule originally gave con? tractors only 15 months to complete their analyses and evaluations. New dates, which willgive EPA more time, are awaiting approval by the U.S. District Court. Another component of the Consent Decree was a list of 65 compounds and classes of compounds (Table 2). A set TABLE 2 The toxic pollutant list Acenaphthene Acrolein 3 Acrylonilrile 4 AldrinlDieldrin 5. Antimony and compounds 6. Arsenic and compounds 7 Asbestos 8 Benzene 9. Benzidine 10. Beryllium and compounds 11. Cadmium and compounds 12. Carbon tetrachloride 13. Chlordane (technical mixture and metabolites) 41. 14. ChIOrinated benzenes (other than dichlorobenzenes) 42. 15. Chlorinated ethanes (including 1.2-dichloroeth? 43. lsophorone one. 1.1.1-trichloroethane, and hexachloroethane) 44. 16. Chloroalkyl others (chloromothyl. chioroethyl. 45. and mixed others) 17. Chlorinated naphthalene elsewhere: includes trichlorophenols and 49. chlorinated cresols) 19. Chlorotorm 20. 2-Chlorophenol 21. Chromium and compounds 22. Copper and compounds 23. Cyanides 24. DDT and metabolites 25. Dichlorobenzenes 1.3-, and 1.4?dichloro? benzenes) 26. Dichlorobenzidine 27. Dichloroethylenes (1.1- and 1.2?dichtoroethylene) 56. 28. 2.4-Dichlorophenol 30. 31. Dinitrotoluene 32. 33. Endosullan and metabolites 34. Endrin and metabolites ol regulations are to be established for the control of the pollutants? in all 2 point-source industrial categories. This list even- tually formed the Toxic Pollutant List included in P.L. 92-500 under Part 307 which concerns toxic materials. The Consent Decree lacked adequate consideration tor the real world analytical problems involved with its implementation Environmental and analytical chemistry play significant roles in ob- taining data upon which these regu- lations are being based. but there were some details that were omitted: - Minimum detection levels were not specified. 0 The list of 65 compounds and classes of compounds could include thousands of pollutants if all com- pounds in each of the classes and all orga nometallic compounds were con- sidercd. 0 Standard methods for collecting and preserving the organic samples were unavailable. . Standard methods for analyzing organics in complex waslcwatcrs were unavailable. Nevertheless, contracts were let as mandated, samples were taken and analyses were begun. Concurrent with these activities. EPA chemists were trying to resolve some of the analytical problems caused by the Toxic Pollu- tant List. At an informal meeting in Kansas City in late October 1976. we proposed that the initial (Screening Phase) analyses for the organic pollu- tants be conducted by gas chroma- tography?mass spectrometry (GC- MS). GC-MS was the only available technique that could identify a wide variety of compounds in many differ- ent matrices and in the presence of interfering compounds. Previous ex- perience with natural and drinking water samples had shown that many compounds in water could be identified and semi-quantified at the 1 part per 35. 36. Fluoranthene 37. Haloethers (other than those listed elsewhere; includes chlorophenyiphenyl esters, bromo- other. ether. bis(chloroethoxy) methane, and poly- chlorinatod diphenyl others) 38. Halomethanes (other than those listed elsewhere; includes methylene chloride. methyi chloride. methyl bromide. bromotorm. dichlorobro? momethane. trichlorotluoromethane, dichlo- rodifluoromethane) 39. Heptachlor and metabolites 40. Hexachlorooutadiene 46. Naphthalene Hexachlorocyclohexane (all isomers) Hexachlorocyclopentadiene Lead and compounds Mercury and compowid 47. Nickel and compounds 18. Chlorinated phenols (other than those listed 48. Nitrobenzene Nitrophenols (including 2.4?dinitr0phenol. dini- trocresol) 50. Nitrosamines 51. Pontachiorophenol 52. Phenol 53. Phthalate esters 54. Polyehtorinated biphenyls (P085) 55. Polynuclear aromatic hydrocarbons (including benzanthracenes. benZOpyrenes. benzoilu- oranthene, dibenzanthraeenes, and Selenium and compounds 57. Silver and compounds 29. DiclilorOpropano and dichloropmpone 58. (TODD) 59. 60. Thaliium and compounds 61. Toluene 62. Toxaphene 64. Vinyl chloride 63. Trichloroethylene 65. Zinc and compounds Volume 13. Number 4. April 1979 417 level rising computer GC-MS. Therefore, ll) ggested as a reasonable level to lyze for in industrial effluents. Analytical minimum detection lev- els for many pesticides already existed in the Federal Register, so it was sug- gestcd that those standard methods and detection levels be used to analyze for pesticides and polyehlorinated bi? phenyls (PCBs). However, a problem still existed with of ana? lyzing for so many classes of organic compounds in the Toxic Pollutant List. The challenge of chemical analysis of a sample for literally thousands of components is staggering-?-espeeially when these components may be at pa rt per billion levels in a complex sample matrix. The expenditure of resources in government as well as private labo- ratories would be overwhelming if analyses were attempted for all possi- TABLE 3 ble Chemicals on the original list of compounds and compound classes. in order for contractors to be able to submit costs for conducting analyses, they had to at least have a ?nite list of compounds to be analyzed for. Therefore. a second meeting was held a few weeks later in Atlanta to resolve the Consent Decree Toxic Pollutant List into one that was contractually and analytically manageable. in addressing the l3 metals on the Toxic Pollutants List the term, .. and their compounds," was interpreted to mean ?total metals,? which would include both inorganic and organe- metallic compounds. The standard method for analysis of total cyanides was selected and asbestos methodology was deferred until later. This left a list of 50 categories oforganic pollutants. Not counting tosaphcne. and chlordane. there were l8 groups of organic pollutants. each containing 2 to 50 compounds. To resolve these groups into a list with finite propor- tions required decisions that addressed the Consent Decree. Four criteria were employed to prioritize and select specific repre- sentative compounds for each group. This provided the required specificity necessary for developing analytical methods and for contract management without excluding other compounds in those classes that may be of future concern. 0 All compounds specifically named in the Toxic Pollutant List (Table 2) were automatically included. The availability ofchemieal standards for verification and quantification was considered mandatory. Therefore, every representative compound added had to be listed in at least one chemical supply catalog. EPA list of 129 Priority Pollutants and the relative frequency of these materials in industrial wastewaters Percent Number 01 Percent Number 01 lnduslrlal 0! Industrial sample: 6310991193 DI samples 3 categories 31 are purgeable organics 1.2 5 Acrotein 2.1 5 1.2-Diehlor0propane 2.7 1O Acrylonitrile 1.0 5 1,3-Dichloropropene 29.1 25 Benzene 34.2 25 Methylene chloride 29.3 28 Toluene 1.9 6 Methyl chloride 16.7 24 0.1 1 Methyl bromide 7.7 14 Carbon tetrachloride 1.9 12 Bromotorm 5.0 10 Chlorobenzene 4.3 17 Dichlorobromomethane 6.5 16 1.2-Dichloroethane 6.8 11 10.2 25 1.1.1-Trichloroethane 0.3 4 Dichlorodilluoromethane 1.4 8 2.5 15 Chlorodibromomethane 7.7 17 1.1-Dichloroethytene 10.2 19 TetrachlorOethylene 1.9 12 1.1.2-Trichloroethane 10.5 21 Trichloroethylene 4.2 13 1.1.2.2-Tetrachloroethane 0.2 2 Vinyl chloride 0.4 2 Chloroethane 7.7 18 1.2-trans-Dichloroethylene 1.5 1 2?Chloroethyl vinyl ether 0.1 2 ether 40.2 28 Chioroiorm 46 are baselneutral extractable organic compounds 1.2-Diehlorobenzene 5.7 11 Fluorene 6.0 9 1.3-Diehtorobenzene 7.2 12 luoranthene 1.4-Diehlorobenzene 5.1 9 0.5 5 Hexachloroethane 7.8 14 Pyrene 0.2 1 Hexaehlorobutadiene 10.6 16 {Phenanthrene 1.1 7 Hexachlorobenzene Anthracene 1.0 6 1.2.4-Trichlorobenzene 2.3 6 Benzo(a}anthracene 0.4 3 bis(2-Ctiloroethoxy) methane 1.6 6 Benzo(b}iluoranthene 10.6 18 Naphthalene 1.8 6 Benzotkittuoranthene 0.9 9 2-Chloronaphthalene 3.2 8 Benzotalpyrene 1.5 13 ISOphoronc 0.8 4 1.8 9 Nitrobenzene 0.2 4 Dibenzotamanthracene 1.1 3 2.4?Dinitrotoluenc 0.6 7 Benzotg.h.i)perylone 1.5 9 2.6-Dinitrotoluene 0.1 2 4-Chlomphenyl phenyl ether 0.04 1 4~Broniophenyl phenyl ether 0 0 41.9 29 phthalate 0.2 4 Benzidine 6.4 12 Di-rroctyl phthalate 1.1 4 bist2-Chlor0ethyl) ether 5.8 15 Dimethyl plithatate 0.8 7 7.6 20 Diothyl plithalate 0.1 1 Hexaehlor0cycl0pontadiene 18.9 23 Di?n?bulyl phthalate 1.2 5 ?8 Environmental Science a Technology ?requcncy of occurrence of the presentalive compound in water was an important consideration. All com- pounds except those named in the Toxic Pollutant List were considered ifthey were found with a frequency of 25% of the total known listings for that class of compounds. 0 Chemical production data were used as a guide for prioritizing choices when they were available. A draft manuscript ofan EPA re- port listing all known organic pollu? tants (other than pesticides) identified worldwide in water through June 1976. was used for the criterion of whether a compound was a recognized water pollutant (Shackelford and Keith. Frequency of Organic Com- pounds ldentified in Water. lil?A? Ten organic chemical catalogs were searched to determine whether chemical standards were Percent Number 01 commercially available. l?inally. Stanford Research Insti- lutc's Directory 01' Chemical Producers. and Radian Cor- poration?s ?Organic Chemical Pro- ducers? Data Base Program? were used to gather data concerning man? ufacture of various candidate com- pounds. A list of 23 materials was fi- nally compiled and submitted to the environmental plaintiffs in the Consent Decree. At their request. live addi- tional Aroclors and dim-octyl phlhal- ate were added to raise the total to 129 (counting the Aroclor mixtures. chlordane. toxaphene. and asbestos each as a Priority Pollutant). Table 3 summarizes this list and also indicates the relative frequency with which these compounds are being found in industrial wastewaters. Once the Priority Pollutants were de?ned as a finite list of materials it The priovity pollutants can be divided into nine groups was possible to develop a sampling and analysis strategy: 0 metals 0 asbestos . total cyanides pesticides . compounds extracted under acidic conditions 0 compounds extracted under al- kaline conditions . neutral extractable compounds - total phenols purgeable compounds Because oftheir availability. it was decided to use standard pesticide methodologies for the analysis of pes- ticides and their metabolites. This usually involves extraction. Florisil column cleanup of the concentrated extract and gas chromatographic Percent Number of 01 lndustrlal at Industrial samplesa categoriesb samples ?1 categerleeb 4.5 . 12 0.1 1 N?Nitrosodimethytamfne 4.2 14 Acenaphthene 0.1 2 N-Nitrosodi-n?propyiamine 8.5 13 Bulyi benzyl phtitalate 1.4 6 ether 11 are acid extractable organic compounds 26.1 25 Phenol 1-9 8 pChloro-mcresot 2.3 11 2?Nitrophenol 2.3 10 2-Chlor0phenot 2.2 9 4-Nitrophenol 3.3 12 2,4-Dichlorophcnol 1.6 6 2.4?Dinitrophenol 4.6 12 2.4.6-Trichlorophenol 1.1 6 5.2 15 6.9 18 Pentachtorophenol 26 are pesticides/PCB'S 0.3 3 a-Endosullan 0.3 3 Heptachlor 0.4 4 B-Endosuttan 0.1 1 Heptachlor epoxide 0.2 2 Endosulian suitate 0.2 4 Chlordane 0.6 4 ?43110 0.2 2 Toxapheno . 0.8 6 0.6 2 Aroclor 1016 0.2 4 6-BHC 0.5 1 Aroclor 1221 0.5 3 0.9 2 Aroclor 1232 0.5 5 Aldrin 0.8 3 Aroctor 1242 0.1 3 Dietdrin 0.6 2 Aroclor 1248 0.04 1 0.6 3 Arocior 1254 0.1 2 0.5 1 Aroctor 1260 0.2 2 p-dioxin (TCDD) 0.2 3 Endrin 0.2 2 Endrin aldehyde 13 are metals 18.1 20 Antimony 16.5 20 Mercury 199 19 Arsenic 34.7 27 Nickel 14.1 18 Beryllium 18.9 21 Selenium 30.7 25 Cadmium 22.9 25 Silver 53.? 28 Chromium 19.2 19 Thaltium 55.5 28 Copper 54.6 26 Zinc 43.8 27 Lead Miscellaneous 33.4 19 Total cyanides Not available Asbestos (fibrous) Not available Total phenols The percent 01 samples represents the number of times this compound was lound in all sampies in which it was analyzed for divrrlod by the total as of31 August 1978. Numbers of samples ranged [rpm 2532 to 2999 with the being 261?. A total 01 3? industrial categories and subcategories ware anatyze-d lor organics and 2t} lor metals as 0131 August 19:8. Volume 13. Number 4. April 1979 419 ..-- a an electron capture cc there were few basic s, this group was combined neutral compounds. The acid actable Priority Pollutants in- ude only phenols. The remaining organic compounds, with the exception of acrolein and acrylonitrile, were readily purgeable from aqueous solu- tions. The latter two were analyzed by direct aqueous injection GC-MS. There are three phases of analyses involved with the Priority Pollutants. The initial work is referred to as the ?Screening Phase.? objective is to de?ne which ofthc Priority Pollutants are in the treated and untreated wastewaters of each of the industrial categories. The second ?Verification Phase? is to determine the ef?ciencies of the various treatment technologies under consideration. The final ?Monitoring Phase" will be used for compliance monitoring of state and federal discharge permits. The three phases of analyses include screening, verification, and monitoring. The screening phase is 85% complete; verification 40% complete, but the monitoring phase has not yet beeri initiated A semiquantitativc analysis by GC-MS is all that is required to achieve the objective of the Screening Phase. Three characteristic fragment ions were chosen for each compound and chromatographic methods were devised that would allow unambiguous identi?cation of each compound (with few exceptions). - Tom Bcllar and Jim at EPA's Environmental Monitoring and Support Laboratory in Cincinnati. Ohio, had been investigating a purge and trap method for analyzing very volatile organic compounds in water. and this technique was applied suc- cessfully to 29 of the Priority Pollu- tants. The late Ron Webb. at Environmental Research Laboratory in Athens, Georgia, had been investi- gating liquid-liquid extraction and various concentration methods for isolating intermediate volatile organic compounds front water: these tech- niques were applied successfully to S7 ofthe Priority Pollutants. [Eleven of the extractable compounds are phenols extracted under acidic conditions with methylene chloride. and 46 are neutral and basic compounds extracted under alkaline conditions with the same sol- vent. The 26 pesticides are extracted with a methylene chloride-hexane mixture, using a separate aliquot of 420 Environmental Science a Technology . a- - 5 is. . lash-3 -- ?aws?. ?g?gmu-AIT. 4 ?sh ?li 523'. - ?irt/L. ?it - . -- Nun?Hm I if. our .L. 5 Pesticide analysis. After attraction an aliquot is injected into a gas wastewater. The purgeablc sample requires a third aliquot ofwastcwatcr collected separately. The decision was made to use con? ventional packed columns for all chromatographic separations even though it was realized that capillary columns would provide superior reso- lution. Because most laboratories had had little experience with capillary columns, and since the identifications and quantifications were to be based on selected characteristic ions within a small retention time ?window,? it was not necessary that complete chromatographic resolution ofall or- ganic Priority Pollutants be achieved. To preclude omission of other or- ganic compounds potentially included by the classes of compounds in the Toxic Pollutants List. all data are being committed to permanent storage on magnetic tape. Likewise. the organic extracts are being scaled and stored at subzcro temperatures at the Athens, Georgia. Environmental Research Laboratory. These extracts and GC-MS tapes make up the most extensive and representative cross- section ofdata on organic compounds in industrial wastcwaters that has ever been compiled. These will be examined further for additional compound identifications over the next several years. Water samples for the purgetthle are collected itt 40-ml. glass vials with Te?on-lined septa. The vials are completely filled so no bub- bles are present. Usually 5 ml. of this sample. spiked with bromochloro- methane and .-l-dichlorobutanc as internal standards. is used for the analysis. After being transferred to a glass sparging to be with a fritted-glass bottom, the sample is purged with he- lium. The volatile organics are stripped from the water and adsorbed in a stainless steel trap packed with Tc- nax-GC and silica gel. At the com- pletion of the purging step, the gas flow to the trap is reversed and the trap is rapidly heated to 180 The organics a re thermally desorbed from the trap to the head ofa gas chromatographic column held at room temperature. When desorption is complete the chromatographic column is tempera- ture programmed and the organic compounds are eluted into a corn- putcr-controllcd mass spectrometer where they are identified and quanti? ?ed. initially acrolein and acrylonitrile were analyzed by direct aqueous in- jection. but as of September I978. the EPA has authorized an optional analysis using the purge and trap technique. Problems with the Screening Phase methods that have not been resolved - Several compounds required about 200 ng instead of 40 rig for minimum detection. 0 and anthra- cene are indistinguishable. - dc- composes to azoben/cne and nitrosodiphenylaminc decomposes to diphenylaminc. - gives a broad low chromatographic peak. . Direct aqueous injection of acrolein and acrylonitrilc suffers from low sensitivity and the purging efficiency for these compounds is variable. In spite of these difficulties the Screening Phase Protocol is sue- eessful for the great majority of the Priority Pollutants. lixtractahles. Two liters of ater from a 3-day composite sample are made strongly alkaline and ex- tracted with methylene chloride. The extracts are concentrated in two stages, using ?rst a Kuderna-Danish concentrator and second a micro- Syuder column. An internal standard ofdm-anthracene is added to the LO mL concentrated extract, which con- tains all the ?Base/Neutral Priority Pollutants.? The same 2 I. of water is then made strongly acidic and reex- tracted with methylene chloride. Concentration and addition of the same internal standard produces the extract containing all of the ?Acidic Priority Pollutants." Injection of 2 ul- of these extracts into a GC-MS pro- vides a minimum of 40 ng ofcach ex- tractable Priority Pollutant at l0 parts per billion or more in the water and 40 ng of the internal standard. The orig- inal GC column packing for Base/ Neutrals SP-2250 on Supelco- port) has been replaced by 1% SP- 2250 DB on Supelcoport. The original GC column for the Acid Extractables (Tenax-GC) has been replaced by 1% DA on Supelcoport. These new column packings provide better chromatographic results than the original packings, and the EPA has purchased large lots which it provides to all of its regional and contract lab- oratories in an effort to make all analyses as uniform as possible. For pesticide analyses :1 separate liter of water front the composite sample is extracted with hexane/ methylene chloride. concentrated to 10 ml- and the extract is fractionated on a Florisil column. Analysis of the pes- ticide extracts requires GC columns used for standard pesticides work under isothermal conditions and an electron capture detector. Pesticides identified using these methods must be I confirmed by GC-MS. An automated software program completed identi?ed the presence or absence of the organic priority pollutants and quantifies them within minutes Computer-controlled analyses lend themselves to cont- puter-assisted analyses and several laboratories are developing various deg rees ofautomatcd analyses. Radian Corporation. for example. has an au- tomated software program that ana? lyzes the mass spectral data and. on the basis of fragment ions and their correct ratios. relative retention times. ion in- tensities relative to the internal stan- dard and response factors. completely n- . 6 4i 1 t?zm its." a ii I Ive-y": - .91?gs? agghi?ri . L. Elemental analysis. Technicians are using rented AA transfer the presence ofmetals identifies the presence or absence of the organic Priority Pollutants and quantifies them within minutes. Manual processing takes 3 to 4 hours to achieve the same results. Statistical analyses of more than 4500 data points revealed only 0.13% false-positive and 0.04% false-negative computer identifications at a concen- tration level greater than 10 ppb. Au- tomated GC-MS analyses of the Pri- ority Pollutants, while not yet ap? proved methods. are obviously the coming trend. The EPA intends to evaluate the performance of the most promising of these computer programs in the near future. Not only are com- puterized analyses most cost effective, they do not use highly trained people to do what will eventually become routine analyses. Furthermore. the computer does not tire of performing tedious repetitive functions over long periods of time and is less likely to make errors than a human. The Metals. All of the metals anal- yses performed during the Screening Phase and a large number of metals analyses from the Veri?cation Phase are being analyzed by the EPA Cen- tral Regional Laboratory in Chicago. The primary reason for utiliring one laboratory for metals analysis was that the Chicago Regional Laboratory had an indactively-coupled plasma argon emissions spectrometer which it had been using for over a year fora of surveys. This regional laboratory developed and maintained both the quality assurance program and the data file for all 2i industries. The samples are collected in plastic containers and originally were pre- served with nitric acid before ship- ment. llowcver. US. Department of Transportation (DOT) regulations prohibit shipping nitric. acid by air in any concentration so this practice has been discontinued. Now these samples are shipped unpreserved. acidified upon receipt at the laboratory. and are held for one week prior to analysis. Total ('yanides and Phenols. Alka- line preservation at a pit of 12 or greater is necessary for the cyanides when the samples are collected. Again. these preservation requirements run afoul of DOT airfreight regulations. Therefore. these samples are now shipped by surface transportation. They must be analyzed within 24 hours of receipt at the laboratory. Analysis of total eyanides is by the standard colorimetric method. After the sample is acidified it is re?uxed for several hours and hydrogen cyanide is collected in an alkaline solution. Abs sorbance is measured at 578 nm in the colored solution produced by adding pyridine and barbituric acid. Total phenols. for the purpose ofelarity. are those compounds that are measured by the 4-aminoantipyridine method. Water samples for total phenols-are collected in glass bottles. acidified to Metals analyzed by inductively coupled plasma emission spectrograph Aluminum Magnesium Barium Manganese Boron Molybdenum Cadmium Nickel Calcium Silver Cobalt Tin Copper Titanium lron Vanadium Lead Yttrium Chromium Zinc Metals analyzed by flameless atomic absorption Antimony Arsenic Selenium Thallium Mercury Volume 13. Number 4, April 1979 421 v. -..- .- u?w . Priority Concentration fractionation Mraclor pollutants methods methods Southwest 6 phthalate Extract with Florisil or Research esters CHQCI, alumina institute (SWRI) 2 Monsanto 7 halo- Extracl with Florisil ethers 3 Hydro- 9 chlori- Extract with Florlsil science nated CH20I2 hydron carbons 4 Battelle 3 nitro? Extract with Florlsil benzenes and iso- exchange phorone with toluene 5 3 nitros- Extract with Florisil amines exchange with hexane 6 Carbo? TODD Extract with Wash with acid rundum and base: carbon and! or silica column 7 Battelle 2 benzi? Extract with Wash extract with dines and ethyl acetate acid. diphen- at pH 8-9 Make acid yihydra- wash alkaline zine? at extract with ethyl acetate 8 Hydro- 11 phenols Extract with 1. None tor 2 science CH2012 at nitrOphenols pH 2 2. Silica gel of pentalluoro- benzyl derivatives of 9 phenols 9 Battelle 16 polynu? Extract with Silica gel; clear acetonitrile aromatics exchange solvent with exchange cyclohexane 10 SWRI 25 pesti- Extract with Fierisil; Collect 3 sides fractions: Hexane solvent exchange 11 Carbo- 26 purge- 1. Purge and None rundum ables trap using Tenaxlsilica gel trap or 2. Extract with pentane 12 Carbo? Acrolein, Direct aqueous None rundum acrylo- injection nitrile and CFZCIZ Tho 11-1 organic priority poiiutanls are divided into 12 groups; 20 laps is so unstable that method development work has mused with it. EPA recommends the! chime-ethyl vinyl other (from Greaip 2), "it: three dirtilurobenzeues to this group. This would raise the number of putgt'ablr.? Priority Pollutants to 31. Detectors ECD Electrolytic conductivity ECD and FID ?rearm" MS Analytical Analytical methods columns Isothermal 1.5% SP- GC at two 2250i1.95% diflerent tempera- tures Temperature 3% SP- program- 1000 med GC isothermal 1.5% GC at two 111.5% ditierent (JV-225 tempera- tures Isothermal 1.5% 0V- GC 17l1.95% OF-1 . Isothermal Carbowax 60 at two 20M different temper- atures Isothermal GC HPLC. Lichrosorb lsocratic elution reverse phase 1. Temper- 1. attire DA program- med GC tor 2 nitro- phenols 2. isothermal 2. 5% GO for 9 OV-W other phenols mac? "??pernh:siaie? Gradient HC-ODS elution reverse phase Isothermal 1.5 SP- GC 2250/ 1.95% SP-2401 store 1000 program- 'med GC 2. Isothermal GC Temperature 0.27 program- Carbowax mod (30 1500 will verify the methods before the (and of this year. 1 Fluorescence 1. PIE) 2. ?00 at two different excitation at emission ECD nonhato- genated compounds. Electrolytic conductivity for halogenated compounds . ECD with err- tracts FID Group 3) and dichlororiilluoronwtimne (from Group 12100 moved Electrochemical with phosphoric acid and chilled. tese samples can be shipped by air and they must be distilled within 24 hours after receipt at the laboratory. 4-Aminoantipyridine is added to the distillate and the resulting dye is ex- tracted into chloroform and its ab- sorbancc is measured at 460 nm. Asbestos. Since there are many types of asbestos the first problem was how to?de?ne it. Asbestos was de?ned finally as ?fibrous asbestos" and con- sists of To isolate the fibers, water is filtered through a Nuclepore filter and the retained particulates are carbon coated under vacuum. The or- ganic filter is dissolved with chloro- form, leaving the fibers embedded in a carbon film. A portion of the film is magnified 20 000 times with a trans- mission electron microseope, and the asbestos fibers are identified by se- lected area electron diffraction. A representative area of the electron microscotie grid is counted, and the concentration of aststos in millions of fibers per liter can be calculated from the size of the water sample. Protocol Reviews. Periodically representatives from EPA. industry and the contract laboratories meet to review common problems. new ana- lytical techniques and the status ofall programs. These meetings have pro- vided an excellent forum for the shared experience of the chemists involved in these analyses. in many. if not most cases. split samples are provided to the industries involved so comparisons of the data and the methodology can be made. To date no fewer than nine in- dustrial work groups have made im- portant contributions to the ever con- tinuing review and refinement of the analytical protocol. The Verification Phase is designed to provide a basis for developing new source performance standards. pre- treatment standards and BAT regu- lations. Plants within an industrial category are chosen to encompass various treatment technologies and wide geographic areas. In general. only Priority Pollutants identified during the Screening Phase are reanalyzed in their respective industrial categories in this phase. Conventional pollution parameters (for example, BOD, TOC, and are also measured along with the Pri- ority Pollutants. The sampling and analytical methods are varied and de- pend on the chemical process treat- ment technology being evaluated and the parameters selected for verifica- tion. Analytical methods may include those in the Screening Phase protocol. only (3C using packed or capillary columns and specific detectors. high pressure liquid chromatography or any combination of the above. The Monitoring Phase will use less expensive methods than GC-MS whenever possible. l?ive contracts. to- taling $1.5 million, are aimed at de- veloping and verifying alternate methods to for analyzing the organic Priority Pollutants. These methods concentrate on sample cleanup and fractionation prior to analysis. Final identification/quanti- fication will be done using 0C and with specific detectors. The I I4 organic Priority Pollutants are divided into l2 groups (Table 4). and methods are trying to be developed that will specifically identify and quantify each ofthc Priority Pollutants in that group in the presence ofinter? fering organic compounds. To verify the methods, wastewaters spiked with solutions of each of the groups will be analyzed. Youden pairs of concen- trates (two solutions with close but different concentrations) will be used for spiking. Twenty and private laboratories will verify the majority of the methods for all 12 groups before the end of l979. The EPA will not necessarily be bound by the methods developed for these 12 groups. Hope- fully some unification will be achieved by taking the best features of methods developed under these contracts and also under some EPA drinking water analyses contracts. Obviously methods developed for drinking water analyses cannot be used for industrial waste- water analyses without modifications to cleanup procedures. But fewer per? mutations tnight be achieved using some of the superior cleanup methods developed under Monitoring Phase contracts and some of the superior chromatographic conditions developed for analyzing drinking water samples for these same compounds. A first dratt of the methods for the monitoring phase will be promulgated this month The first draft of each method was due in December l?l'ltt. Starting about that time will be a series of interlabo- ratory studies to verify accuracy and precision of each method. if a waste- water contains Priority Pollutants in more than 3 or 4 of the IE groups. it may be more cost effective for a dis- charger to self-monitor for them using Ultimately, there will proh- ably be some industrial Categories that are served best by (EC-MS analyses for self-monitoring, especially in view of the potential new software programs that autotmttically perform the iden? tifications and quantifiealions. With the undertaking of the Priority Pollutant program. the has taken its first step on the long road of using organic analyses for monitoring toxic chemicals in industrial discharges. The Priority Pollutant program is. for the first time. establishing a baseline of information with regard to chemical discharges from industrial point sources. Together with the expanded program covering some 40 publicly owned treatment works (POTWs). an overall picture of the nation's ambient and source discharges is being pro- vided. The l29 Priority Pollutants are only the beginning ofa better way to mon- itor industrial wastewater discharges. The mass spectral data tapes and the stored extracts have yet to be exam- ined. Programs to work with this data will be initiated before this year is out. Through these efforts a further list of compounds may be developed which are of concern to industry, the EPA. and ettrt?ronntenta/ists. Perhaps the compounds that are infrequently found can be removed from the toxic pollutant list' and others more deserving be added. The meth- ods. of course. will continue to improve as technology advances. A larger and more valid data base will be accumu- lated. in the end we should have rea- sonable cost?effective methods for re- ducing industrial pollution and meni- toring for it. And. a all. that is what we started out to tio?nobody thought it would be easy. Dr. Larry II. Keith (I) is manager nj'the Division at Radian Corporation in ?I'm?us. He is rtfso Chairman of the Dt?t?t'st?un of Enri- mnntentnl ('hentistry prior tojut'nt?ng Radian, worker! for EPA at the .?ltltens. Georgy}: Rt??r?tll't'ft Litho- rotary. William A. 'l'elliard is r-Itt'efoftne fz'n? r'rgr and Mining l?/?nent (t'nirfelt'nex Dt?rt'st'on. Pm- tertt?on star-net: Prior to his present puri- tt'rnt, he worked in the Office of It'un'r Enforcement. both in the Permits Dt'r't'sirm and the ?irts-ion. He joined the ugr'tnjt' in [973. Volume 13. Number 4, April 1979 423 - -- .- REVISED Reconranded List 01 Priority Po11utants 1. *acenaphthene 2. *acro1ein 3. *acry1onitri1e 4. *benZQre 5. *benzidine 6. *carbon tetrach1oride (tetrach1oromethane) *Ch1crinated0 ben ezenes (other than dich1o we .zenes) 7. ch1orobenezene 8. 1 2 4- trich1orobenzene 9. hexaeh1orobenzene *Ch1orinete? 1,2? ethane and hexach1creethane) 10. 1,2wdich1oroethene 11. 12. hexach1oroethane 13. 1,1-dich1oroethene 14. 1,1,2? ?tr ich1oroetha.e 15. 16. ch1oroethane *Ch10r0e1kv1 e- thers (ch1oremethy1, ch1oroetnyi an: uxec etners) 17. bis(ch1oromethy1} et.er *Specific compounds and chemica1 c1asses as 11sted 1n the consent degree. 20. 21. 22. 23. 24. 25. 27. 28. 29. 30. 3l. 32. 33. bis{2?chloroethly) ether 2-chloroethyl vinyl ether (mixed) *Chlorinated neohtalene 2-chloronephthalene *Chlorinated phenols (other than those listed elsewhere; includes trichloro- phenols and chlorinated cresols) 2,4,6-trichlorophen0l cresol *chloroform (trichloromethene) *Z?Chlorophenol *Dichlorobenzenes _l,2?dichlorobenzene l,3?dichlorobenzene 1,4?dichlorobenzene *Dichloroben2idine *Dichloroethylenes (l,l-dichloroethylene and l.2?dichloroethylene) l,l-dichloroethylene *2,4-dichlorephenol *Dichloropropane and dichloropropene l,2?dichloropropane l,2-dichlorOpropylene (l,3-dichloroprcpene} *DinitrotoTuene 35. 2.4?dinitroto1uene 36. 2,6,-dinitrotoluene 37. *1,2-diphehy1hydrazine 38. 39. *f1uoranthene *Haloethers (other than those 1isted elsewnere) 40. 4-ch10ropheny1 phenyi ether 41. 4?br0mopheny1 pheny1 ether 42. bis(2?ch10roisopropy1) ether 43._ bis(2-ch1oroethoxy) metrene *Ha10methanes (other than those 1isted sewnere) 44. methylene chioride (dich1oromethane) 45. methy1 chloride (chloromethane) 46. methy1 bromide (bromcmethane) '47. bromoform (tribromomethane) 48. dichTorobromomethane 49. 50. De La TU) 51. chlorodibromomethane 52. *hexachlorobutadiene 53. *hexach?orocycTopentadiene 54. *isophorone 55. 56. 57. 58. 59. 60. 66. ?67. 68. 69. 7o. 71. *naphtha19ne *nitrobenzen *Hitropheno1s (including 2,4?dinitr0phen01 ana a1n1trocreso1) 2?nitrophen01 4-nitr0pheno] *2,4?dinitrophen01 *Nitrosamines N-nitrosodimethy1amine N-nitrosodiphenylamine *pentach1orcpheno1 *pheno] *Phthalate esters bis(2-ethy1hexy1) phthaiate buty1 benzy] phthaiate di-n?butjl phthalate di-n-octy1 phthalate diethyl phtha1at? dimethyI phthalate *Po11nuc1ear aromatic hvdracarbons benzo(a)anthracene (1.2~benzanthracene} 73. benzo pyrene (3,4?benzopyrene) 74. 3.4?benzof1uoranthene 75. benzo(k)f1uoranthane (11.12-benzof1uoranthene) 76. 77. 78. anthracene 79. benzo{ghi)perylene (1,12?beniopery1ene) 80. f1uroene 81. phenathrene 82. dibenzo (a,h)anthrecene (1,2,5,6-dibenzanthracene) 83. indeno (2,3ao-pheny15nepyrane) 84. pyrene 85. 86. *toluena 87. *trich10roethy1ene 88. *vinyl ch1oride (ch10roethy1ene) Pesticides and Metaboiites 89. *a1drin 90. *dieldrin 91. *chlordane (technica1 mixture 5 metabo1ites)_ and retaboT?tes 92. 93. 94. *endosu1fan and metabolites 95. a-endosu1fan-A1pha 96. b-endosu1fan-Be?a 97. endosu1fan su1fate *endrin and metabo1ites 98. endrin 99. endrin a1dehyde *heotach1or and metabo1ites 100. heptach1or 101. heptach1or epoxide hexagd erocyc1ehexane (311 isomers} 102. a-BHC-A1pha 103. b?BHC?Beta 104. (1indane)?Ga??a 105. ta *po1ych1orinated bipheny1s (PCB 106. PC8-1242 (Aroch1or 1242) 107. PC8-1254 (Aroch10r 1254) 108. PCB-1221 (Aroch1or 1221) 109. PC8-1232 (Aroch1or 1232) 110. PCB-1248 (Aroch10r 1248) 111. PCB-1260 (Aroch1or 1260) 112. (Aroch1or 1015) 113. *Toxaphene 114. *Antimony (Tota1 115. *Arsenic (Tota1) *Asbestos (Fibrous) 117. *Beryllium (Total) 118. *Cadmium (Total) 119. (Total) 120. *Copper (Total) 121. *Cyanide (Total) 122. *Lead (Total) 123. *Hercury (Total) 124. *Nickel (Total) 125. *Selenium (Total) 125. *Silver (Total) 127. *Thallium (Total) 128. *Zinc (Total) 129. tetrachlorodibenzo~p~dioxin (TEES) ?Specific co590unds and chemical classes as listed in the consent degree. **This compound was specifically listed in the consent degree. Because of the extreme toxicity (TCDD). He are reccrmending that laboratories not acquire analytical standard for this compound. January 23, 1985 President Ronald Reagan The White House Washington, D.C. Dear Mr. President: Today we are making public a Public Citizen Health Research Group report based on data obtained from the Federal Centers of Disease Control (CDC). The report lists the names of 249 workplaces in 42 states where a total of over 200,000 American workers have been exposed to chemicals and other substances which government studies by CDC's National Institute of Occupational Safety and Health in those workplaces have shown to be linked with an increased risk of cancer, heart disease, or lung disease and other-health problems. Although the government has the names of these workers, and government doctors in CDC and NIOSH are strongly in favor of individual notification, your Administration refuses to spend its resources to save the lives and protect the health of many of these workers by individually notifying them that they are at increased risk so they can get medical help. This can be done, as shown successfully in the case of Augusta Chemical Company in Augusta, Georgia as discussed in the accompanying report. In a letter to you dated October 22, 1984, we asked you to immediately order individual notification of these 200,000 workers and also asked for an explanation of past failures to notify. Then HHS Assistant Secretary for Health Dr. Edward Brandt responded in a November 13, 1984 letter which pointed out that 'we believe individual worker notification is an important issue,?. but failed to explain why a $4 million budget request from CDC (FY 1985) was turned down. We believe the real reason why your administration was unwilling to fund individual worker notification is that in some instances, workers who learn that they have contracted bladder cancer, for example, because of their workplace exposure, might file suit. Your administration seems more zealous about protecting companies from paying the real costs of doing the kind of business which injures or kills workers than in allowing workers to find out sooner, rather than too late, that they are at increased risk of cancer and other diseases. Which America are you the leader of? Si re . Sidney olfe, H.D. Mess Watp?if Critical Mass Energy Propel: _Hea? h Research Group-- Litigation Group Tax. Heloun Group 1-w- 1_ 3; ?gm . i; January 23,?1985 PUBLIC CITIZEN HEALTH WESEARCH GROUP REPORT ON NIOSH SHOWING WORKER .HEALTH RISKS rj?u This week we obtained v1a the Freedom of InEOrma?tion Act, :summaries of studies by the National Institute of OccupationaL blyc?c ti?ien ?SaEety -and Health (NIOSH) which discloSed, for the EirSt t1me,s? tions had prevIously determ1ned over 200, 000 workers to be '?increased risk of' cancer., lung disease, heart disease and other? . health problems. NIOSH and Centers for Disease Control if _dOctors and scientiSts have recommended that individual notifi- 5catIOn Of all Of these workers be undertaken. NIOSH knows 1' . rthe names_ and 10catiOns- Of 253. workplaces where NIOSH investiga_- the identity of mast at these workers but the. Reagan Administra- tion has rejected a budget requeSt from CDC Eor such notIEIcation.vm F. 0f the more than 200 000 workers who were identiEIed as being at increaSed riSk and Eor whom NIQSH recommended not1Eica?? t-idn, one purpose of notification cited by NIOSH EOr.a11 200, 000 workers improvements in working cenditions.r In the accompanying charts, each workplace has e.ither A, 8, pr at. the righ-t end of the '1ine. This is way of categorizing 1.x! studies according to the purpose of not1E1cat10n.c .2 Category A: (86 WORKSITES, 110, 005 WORKERS) . "Studies in which participants could gain -direct medical/health benefits Erom noti- 5 ficatiOncategory a: (136 WORKSITES 137, 965 WORKERS) "Studies in which participants are potentially iare no knOwn eEEeCtive interVention methods," Category c: (27 WORKSITES, 6 508 WORKERS) a~ - ?Studies in which indiv'idual participant notification would stimulate -improvements in working conditsons..' . 1 The best evid ence 0E .how important and 1.iEe saving such notiEication. is comes from a pilot project in AUgus-ta, Georgia* involving the Augusta Chemical Company and exposure of workers to (BNAJ., known to cause bladder cancer. As result of the pilot notification and screening program, 13 out? of 586 screened workers were found to have bladder cancer with 26 additional workers having tests highly suggestive of pre- ma1ign-ant changes.? Health Research Group 0 2000 P'Streot N.W. 0 Washington, DC. 20036 0 (202) 872-0320 ..- -.- .. 1?1" 11-. .-. I. [9'33 A .. at high risk and should be .notified but there? .12 a i I i of Workers State City giant. Exposure Disease ?xposed Category . . . ?gs TX Allamore Pioneer Talc_ aResp. disease-l of 7 sites Talc '(pleurai ?with total oE thickening) 303 TX Arlington Oil States OSHA regu? cancer 1 of 9 sites ?0 Rubber lated carci? with total of nogens 179 . 1 . TX Deer Park Shell Epichloro? Same of 2 sites A hydrin with total of 064 TX Edinburg Tide Pro? 1,2?Dibromo- Cancer, re? 1 of 6 sites 8 ducts, Inc. 3~?hloropr0+ productive with total of pane (DBCP) effects 3231 TX Freeportr 993 MiXed ex- Brain cancer 2096 Chemical posures TX Palestine Southern Talc Resp. disease 1'05 7 sites Clay, Van (pleural with tOtal of Horn thickening) 308 Palestine TX Pt. Arthur Texaco Mixed ex- Brain cancer l'of 3 sites posures with total of . 2000 TX Pt. Arthur Gulf Same Same Same TX Pt. Arthur Mobile Same Same Same . a 1 TX Texas City Amoco same Malignant me? 162 deaths 8 lanoma, brain liver cancer TX Texas City Marathon Same Same 62 deaths TX Texas City Union Same Brain cancer 10,000 -B Carbide TX Tyler Pittsburgh? Asbestos ,Lung cancer, 1 of 11 sites A Corning mesothelioma, with total of asbestosis 4100 TX. Tyler Same Same Same of 8Lsites A with ta} OF 7600 1 I TX van Horn Milwhite Talc Resp. disease 1 of 7 sites Talc I (pleural with total of thickening) . 308 TX Unknown Unknown Cotton dust Resp. disease 1 of 3 states in cotton with total of ginners 286 - State City NegaUnee ??MWhite Pine White Pine Ypsilanti Unknown Deerwood DillOn Duluth Unknown St. Verona Viburnum L0uis, Plant Mather Mine White Pine Mine Same Peninsular Paper Co. IRADO C0. Armour l, 2, 3 Pfizer Co. Duluth Works (0.8. distillates, metal fumes, e1, Steel) Ennis} Alder Union Electric Co Syntex Lead Corp. Silica dust, diesel ex? haust geniidine? derived azoidyes Silica, diesel fumes SiliCa dust, diesel ex- haust Talc Coal tar Disease of Workers Exposed Categor? Resp. disease 1 of 7 sites Resp. Resp. silicosis Cancer Resp. disease silicosis Resp. disease (pleural thickening) Resp., liver, pancreas, disease cancer, cancer, mouth with total of 500 1 of 7 sites with total of 500 of 44 sites 8 with total of 12,318 1 of 6 sites A with total of 38 of at least 10 States with total of 5000 of 43 sites with total of 12, 318 1 of 7 sites with total of 308 i. of 17 sites 8 bow?with Ectal of 59,000: - sulfuric acidthroat cancers. mist, etc. Talc nated bi- phenyls Dioxin Silica dust, diesel ex- haus? I Resp. disease Resp. diseaSe 1.of 7;sites_ (pleural with total of thickening) 308 - Cancer 25? 8 Same 1 of 11 sites with total of ?1400 i ReSp. disease 1 of 44Esites with total of 12,318 I I of Workers State City Plant Exposure DiseaSe Exposed Category MD Baltimore Allied Kepdne Cancer 1_of 10 sites - ChemiCal with total of Company 2269 MD Baltimore Young?Ana? Benzidine Bladder of 3 sites A line Co. cancer with total of 1650 HD Frederick? Unknown Silica dust, Resp. cancer, 1 of 44 sites town diesel ex- silicosis with total of haust 12,318 MD Shadyside Chesapeake dSHALregu? Cancer 1 of 9 sites B- Instrument lated carci-= with total of . Corp. nogens 179 Adrian Anderson 4,4-Methy1? Cancer 549 Development ene?bis Company (chloroani? I line) (MOCA) Calumet Centennia12 Silica dust,'Resp. cancer l_of 44 sites diesel ex? silicosis with total Of haust 12,318 ,ngI Detroit . Amalgamated Perchloro- Cancer 1 of 4 locals Clothing ethylene with total of Textile wer? 1597 kers Union Ironwood . Penokee Silica dust, Resp. cancer 1 of 44 sites -Mine diesel ex- .silicosis with total of haust 12,318 g?rMI Midland- Dow Bis?cthro- Lung cancer? 1 of 6'sites A methyl ether, with total of Chloromethyl 1800 (methyl) ether (BCME, CMME) MI Midland Same Dioxin Cancer 1 of 11 sites an 1 with total of 1 o: . Kg 1? Lno, 140-0 c?e?n??LS ?r?mi #391) A iyf?I Negaunee TraCy Mine Silica dust, Resp. cancer, 1 of 4% sites diesel ex? silicosis with total of haust 12,318l MI Negaunee Mather Same Same Same I Mine :1 ID 90 Unknown Is- . fUdknoWn- i4 ?is: I U?known 'zihugkegqn Haven. ??11 beta mweo Claymont I {f 1 FL Jagpksonv111e gj' -En "fpalmettp? milld mChase'Co} IIDCluett {VPeabody ?(Arrow 1 .1 "fPlant 1. Uranium mines a a? ill UnknOHn Agricultural InseCticidegh Asgrow Eur nium, Same 15 of WOrkeIfs"i Q?ssess ?v .. .1.I m22s ed CaEejof 1 0?14 states A th rium. ra- resp. dise ase, with ;Itota1 of ,Bmmumm, Kepone EDD) Cancer ?Bl?ok Magic K?pone ?Canoer nguthern\ Same Same Same Florida Co.? Shirt) ?..Sgnalloy thylamine Formalde~ 'hyde ?1 2 ?Dibromo-? canoer, re-- 3- -ch10r0pro? productive pane (DBCP) effects Dngcer _Bia?der' cancer Beta?naph? 5000 Ed1Dm isotope tubercu10s1s 4 radon daug.h?. - -.- .411. I: 131 ters. silica same r~same Altered sex 1 of 4 scat?? 1'1 - rat1os in with totalvo? off? spring- Same Uranium, Lung cancer, 1 o? 4 St?teslA thorium, ra? resp. diseaSQ with tota1 ofI vdJUm isotope, 22,000. raqon daugh+ teqs I Lakeway Benzidine . Bladder? 1 0f 3 sites JA ?Qhemicals canoe? I with "ItotaIL- of 4 1650 U?aohnfco;. same =$am?t I?a' ?1 of 10 sites w=ith tOtal of :2269 1? 1 of 10 -sites with Eotal ofI 2269 .. . I 'Ii? mSame II gf?liiB . . . .SlteS Ewith teta1 sites B31 with of I In a study ublished this month on the notification as ects of this project Occup. Med. 27 19-28, 1985), NIOSH scie tists presented striking evidence of the extent to which notified workers who had been exposed to BNA had been previously unaware of the dangers they faced: 42% of workers who were notified had never heard of BNA. 74% of workers were unaware that BNA is harmful. 0f the 26% of workers who had known prior to notification that RNA is harmful, most had learned about this only after they had developed such as h?nn? in their urine, often a sign of bladder cancer. Because this pilot study showed that worker notification and subsequent screening is feasible, and because CDC scientists have said that there is an ethical obligation to individually notify workers, it is indefensible that the Reagan Administration refuses to fund such an effort. In a letter to President Reagan dated October 22 1984, we asked him to immediately order individual notification of these 200, 000 workers and also asked for an explanation of past failures to notify. Then HHS Assistant Secretary for Health Dr. Edward Brandt responded for President Reagan in a November 13, 1984 letter which pointed out that "we believe individual worker notification is an important issue,? but failed to explain why a $4 million budget request from CDC (FY 1985) was turned down. We believe that the real reason why this administration will not fund individual worker notification is that in at least some instances, workers who learn that they have contracted bladder cancer, for example, because of their workplace exposure, might file a lawsuit. The Reagan Administration seems more zealous about protecting companies from paying the real costs of doing the kind of business which injures or kills workers than in allowing workers to find out sooner, rather than too late, that they are at_;pcreased risk of cancer and other diseases. as its; 1? it a 31M. MN 'n the Shadowof?owfilant?. a By IVER pareason Spec?! to The Ne MIDLAND, Mich. When Julius Grosberg moved here from Detroit 42 yearsago. he would leave his foot- steps in the soot blown on the street by the Dow Chemical Company's chim- . ney. The tomatoes he grew tasted funny to his rela- The Tall: lives back in De- I of troll. Aluminum Midland, Mich screens began pit and rot away . after .a couple of tears in the Midland air. "Now look at it as clean as you :ould ask for.? he said the other day uldawept his hand down Main Street. 'Forty-two years in a community and too see a lot of changes, and they've ill been for the better. Places like De- rott go downhill. but here they're bet- er and everybody knows it. There?s [0 sense of panic or hysteria here.? For most of the 37.000 people of Mid- and. changes can be measured by what can be seen and smelled. If the act from the Dow Chemical Compa- y?s huge plant has been eliminated, if he smell of bromide is only intermit- am now. that is progress by any tniitlard, and it is confirmed by years frismg prosperity and cleanliness. But now Midland is beset with re- eutd reports that the Dow plant. the mm. the river water and, by infer- nce. even the people may be con- lmlnaled with chlon?nated dioxins iat were byproducts of a herbicide tat Dow manufactured here until l?9 when perils became apparent. Recently, after national attention - roused on dioxin contamination at lines Beach. Mo.. environmentalists . :newedthargas that Midland has sen Similarly tainted. As a'result. the_ Environmental Protection Agency an- nounced that it would conduct a com- plete analysis of the presence of diox- ris in Midland. But. in the meantime. ome Midlanders wonder if their lealth is being quietly poisoned while there. denying that a problem exists. omplain that the town is being un- airly depicted as an environmental dsamrarea. ?le-$08k Uptoarls forcingthepeo- .- oliveoritwillbeoontaminated.? .. - '8 toe-hm Wgn?pmphets: a. ~t ti "Yin? Time; the environmentalists with their pointed worries about dioxin. a poison so potent it is measured in parts per trillion. or the company that built Mid- land. that created its obvious pros- pen'ty and that says there is nothing to worry about. "For a lot of people. it comes down to who do you believe Dow or some outsiders." said Mary Sinclair. think most people will choose to be- lieve Dow." I The leadership of Midland County held a news conference on March 18 in the auditorium of the Grace A. Dow Memorial Library to combat the ?old statistics. old information and just plain old news" that Philip Van Dam. president 0! the Chamber of Com- merce. said had appeared in the news media about Midland. You could take a hole as big as a 1 football field and 43 feet deep. ?ll it to the top with gin and then add one drop of vermouth. said Scott MacDonald. chairman of the Midland -- County board of commissioners who works as a train operator for Dow. ?That, ladies and gentlemen. is a _?one part per he - word of caution: no not and an? as? TheNcIYort Times/Hardin. in ?For Midland?s residents, Dow means good jobs and low taxes. Dr. Winifred A. Oyen. director of the Midland County Health Depart- ment. said derisively that she had been told that 100 parts per billion ?is equivalent to one hair-breadth in 25 miles." Both examples drew chuckles from the audience that seemed to say. "How could anything that small be worth all this fuss?? John R. Mann. Mayor of Midland. who is also an engineer at Dow. said that the increase in a rare form of can- cer in the towr'that had attracted the attention of environmentalists looked big only because of the very small number of cases 13 in all over 28 years. ?I'm not declaring a disaster." the Mayor said. ?I?m not pleading for Federal aid. I'm not asking President Reagan to declare Midland a national disaster area." Town Ponders Dioxin ?I'm not a scientist but I have faith in Dow?s experts." Richard Diment, the town recorder of deeds, said as he left the news conference. "If I can?t have faith in the people who live here and work here. whose families live . here, who can I believe?? - . . The long-standing prosperity of Midland is almost exaggerated. as against the slow slide into economic: need that much of the rest of Michigan. has experienced in the recent races-f, aton. Dow Chemical employs about: 9,000 of the area's workers. and less -, than a third of these are blue-collar employees. The rest, an economic demographer's dream come true. are highly trained scientific and mana- gerial employees whose style and taste give Midland its tone of being more of a university town than the manufacturing center that it is. According to the Chamber of Com- merce. this rich mix of money and brains has given Midland 3.500 acres of parkland. forests and nature pre- serves. two municipal golf courses, two city swimming pools. 27 baseball and softball diamonds, 41 public ten- nis courts. 14 raquetball courts. and a variety of lesser sportive attractions Mr. Grosberg boasts that Midland's "Center for the Arts is like a little Lin- coln Center." All this and low taxes. about $1.000 a year 'for a $60,000 house. are irons in the fire for Midland's efforts to lure more people and business to town. None of the talk about dioxins and can- cers have helped. ?We?re in the business of trying to get busrness to come here and expand here." said William Welch. executive VICE president of the chamber. The last time Midland got in an en- vironmental uproar was 12 years ago, and the subject was nuclear pswer. Midland was for it. Schools and off ices were emptied to allow 15,000 people to attended a "Midland Wants Nuclear Power Now! rally at the county fair- grounds to protest challenges to a pro? posed COnsumer?s Power nuclear plant next to the Dow complex. Mary Sinclair. a freelance environ- mental writer who is the mother of five Midland children. had led the light to block the plant. and the news- papers carried reports that Dow would move most of its jobs elsewhere if the plant were not built. think the nuclear plant thing was like the dioxin issue." Mrs. Sinclair said. think people are terrible wor- ried. but there has always been this at- titude that Dow is right about every- - thing. The community has been pater- nalized. and they like it that way, but it is shaking the community a lot." Diane Hebert. the mother of two small children. is one of the worried ones. "We're not trying to shut down Dow. we just want an independent as- sessment of the area to find out what the truth is about dioxins." she said. "It's your kid?s health how can you live knowing there could be a problem for them and not do anything?? But Anne Dever, a member of Midland County Board of Gamma- stoners whose husband. Charles, is at Dow employee. (kinks otherwise. "Dow isn't some monster sitting over us." she said, "Dow is its?Midland 13 Dow. and I have enough confidence in - my husband that if there is something wrong. Chuck will know about it, and have the senseto get us out of here. and jobs Table The following is a list of those U.S. EPA Priority Pollutants not found in the current Critical Materials Register compiled by the Michigan Department of Natural Resources. Those materials which are used in, produced in, or are incidental to your Operation and are contained in this list, should be listed in Section I, Part II of the discharge permit application. The discharge of any of these materials must be listed in Section II, Part 8 of the discharge permit application. acenaphthene* Chlorinated benzenes* (other than dichlorobenzenes) a) chlorobenzene b) 1,2,4-trichlorobenzene Chlorinated ethanes* (other than those listed elsewhere) a) 1,1,17trichloroethane 2. b) 1,1-d1chloroethane c) chloroethane Chloroalkyl ethers* (chloromethyl, chloroethyl and mixed ethers) a) 2-chloroethyl vinyl ether (mixed) Chlorinated naphthalene* a) 2-chloronaphthalene Chlorinated phenols* (other than those listed elsewhere a) parachlorometa-cresol 2 i . I ll.) 5?40? Dichloroethylenes* (1,1-dichloroethylene and 1,2-dichloroethylene) a) 1,1-dichloroethylene b) 1,2-trans-dichloroethylene Dichloropropane and dichloropropene* a) (Lil's LYNMEQMQF Dinitrotoluene* a) 2,6-dinitrotoluene f1uoranthene* Ha]oethers* (other than those Iisted e1sewhere) 4?ch1oropheny1 pheny] ether 4-bromopheny1 pheny] ether bis (2?chloroisopropy1) ether bis (2-ch1oroethoxy) methane {3.0 0' DJ ~2va Halomethanes* (other than those listed e1sewhere) a) methy1ene chloride;(dich1oromethane) b) methyl ch1oride;(ch10romethane) c) methy) bromide;(bromomethane) d) bromoform;(tribromomethane) e) dichlorobromomethane f) trichlorofluoromethane g) dichlorodif1uoromethane h) chlorodibromomethane isOphorone* nitrobenzene* Nitrosamines* . V?h?no\ a) N-nitrosodiphenylamine b) N-nitrosodi-n-propylamine 2' 4K - Kn; Dug 44A Phthalate esters* . a) buty1 benzy] phthalate b) diethy1 phtha1ate c) dimethy] phthalate Po1ynuc1ear aromatic hydrocarbons* a) 3,4-benzof1uoranthene b) benzo(k) c) d) acenaphtherne e) anthracene f) g) f1uorene h) phenathrene i) j) pyrene t01uene* Metabolites* of DDT a) b) Metabolites* of endosulfan a) endosulfan sulfate Metabolites* of endrin a) endrin aldehyde Metabolites* of heptachlor a) heptachlor epoxide Isomers* of hexachlorocyclohexane a) a-BHC-Alpha b) b-BHC-Beta c) g?BHC-Delta Asbestos (Fibrous)* *Specific compounds and chemical classes as listed in the consent de ree. Addendum Instructions: Please indicate in the upper right hand corner of the first page of the Discharge Permit Application whether this application is for: A new use An increased use An existing, presently unpermitted use Renewal of an existing permit Modification of an existing permit 014::me Please send the completed application forms to: Hater Quality Division Department of Natural Resources Stevens T. Mason Building P.0. Box 30028 Lansing, MI 48909 MEMORANDUM STATE OF MICHIGAN TOXIC SUBSTANCE CONTROL COMMISSION Lansing Date: June 7, I985- T0: Larry C. Holcomb FROM: Keith G. Harrison/ SUBJECT: Dow PoseyviIIe LandfiII (For 6/17/85 Exer. Sev. Report) Pursuant to the Commission's May 9, 1985 request, staff requested an update from MDNR on the specifics of their investigation regarding the Dow Posey- viIIe LandfiiI groundwater contamination pIume. MDNR reSponded indicating that they had reveiwed an ApriI, 1985, submitted hydrogeoIogicaI summary report from Dow. The report and the accompanying groundwater anaIyses were feIt to be inadequate by MDNR. Specificaiiy, MDNR indicated that report did not adequater define the extent of the contaminants. MDNR has since requested Bow to instaII additional monitoring weiIs between the existing ones and to provide supporting evidence for their hydro- geoIogicaI summary report conciusions. After the weIIs are installed Dow is to institute a reguIar monitoring scheduIe in order to ensure that no contamination escapes from the site. MDNR indicated that they wiiI keep us informed.