From superjicb@email.msn.com Sun, 9 Jan 2000 12:45:15 -0800
Date: Sun, 9 Jan 2000 12:45:15 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distribution systems

Pat,

You wrote:
> Perhaps I misunderstand, but are you saying that Greenpeace and
> other public interest groups should ignore valid scientific findings?
> If so, that would seem to preclude our being perceived as either
> credible or reasonable, don't you agree?

I totally agree.  I am not familiar with the findings that you referred to
and their validity, but that does not mean that I doubt them.  My point was
that from what I've seen, a lot of the chlorine debate and a lot of the
surrounding politics focussed on dueling perceptions more than science.  And
one of the two areas that is used the most to make environmental groups look
the worst regarding chlorine issues, is water chlorination. It is easy for
people on the other side of the issue who want to continue selling chlorine
to promote the general impression that chlorine saves people from dying of
cholera and that environmental advocates, if they could, would let people
die rather than use chlorine.  Similar logic was used by a poster last week
when he said the WHO preferred DDT to malaria.  Preferring chloirne to
cholera is pretty much the same logic.  I live in the Dallas area where lots
of water chloirnation has been replaced by ozone, but not for residual
treatment.  If we now know that chloirnation is not needed for residual
treatment, then great.

> The fundamental issue is not whether or not we want chlorine to be
> used for residual water treatment.  It is that we want drinking
> water that is free of pathogens and toxic chemical
> contaminants.   I trust that you will agree that this is an entirely
> reasonable need, not a fanatical desire.  The Canadian study
> demonstrates that residual chlorine does not achieve pathogen-
> free water and, based on numerous other studies, the treatment of
> water with chlorine generates toxic chemical contaminants.

Yes great.  Certainly chlorine is a deadly toxic. If today there are
alternatives to chlorine here, or if there is research showing chlorine does
not do the job in pathogen removal, then drinking water free of toxics is
the way to frame the issue so that it can not be used against you.  I'm not
familiar with these studies.  Would you please send me the site reference
again.

Connie Hansson







From Evertcc@aol.com Sun, 9 Jan 2000 16:57:17 EST
Date: Sun, 9 Jan 2000 16:57:17 EST
From: Evertcc@aol.com Evertcc@aol.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking
 water distr...

Connie,

I would be more interested in knowing about any contamination from the PVC 
pipe now used in many water systems than of the chlorination of the water 
itself. 

My other concern is the combination of chlorine and organic compounds to form 
triholomethane for example. I don't think that we can just look at free 
chlorine by itself.

Carl





From burnt_paper@hotmail.com Sun, 09 Jan 2000 23:11:26 GMT
Date: Sun, 09 Jan 2000 23:11:26 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] "normal background level"

Hi Connie

>Have you had any experience working on environmental issues with
>politicians?  If  "no politician can ignore the logic" then we wouldn't
>still be discussing dioxin and incineration<snip>

if I can try to paraphrase your line of reasoning, I think I would agree 
with you; I understand you to be agreeing about the value and utility of 
fact-based argument, but them dang' politicians are mighty slippery beasts !

>Run a CFCs time line versus a dioxin/incineration time line.  My memory is
>not perfect on this issue but I think the dioxin/incineration relationship
>came to be know first.  Why is it so far from being fixed ? <snip>
>Also if you remember there were a core of
>scientists that swore the whole CFC hole was a fabrication.  It was just
>because industry and environmentalists pulled together that the job got
>done.

I think I will vary with you here. My understanding, and it is fairly clear, 
is that there was an overwhelming scientific consensus that CFCs were a 
clear and present danger. I believe that there are reports from the National 
Academy of Sciences, etc. Scientific journals like Nature and Science were 
very clear on this, and while there was debate on the size of the hole, 
whether it was 'natural' or not, etc., it rapidly became impossible to state 
that the hole was a fabrication or, that CFCs were not plausibly involved. 
This was the basis for incredibly convincing argument.

I think you are right about some of the practical problems which you raised 
about the difficulties of reducing dioxin emission, but for my money, I 
would point out to you that there is considerable lack of consensus about 
the 'safe' level for dioxin. For example, Canada and the UK have an 
Tolerable Daily Intake (for TCDD) 1000 fold bigger than in the US; the WHO 
limit is 100-400 x bigger than the US TDI. The point I am making (without 
taking sides !!) is that there is no clear scientific consensus.

>I didn't get into the sedcore file as it would take download time and it
>seemed from your statement that again they didn't tell you why the dioxin
>was there to begin with. I do not know what industry was on these lakes or
>where they were, but I'd bet that they had bleached paper mills on them.

The stated aim of the papers was to find out about the 'background' level of 
dioxin contamination of the environment, rather than to look at pollution 
associated with particular paper mills. Nonetheless, you are quite right 
that there may have been paper mills there; I don't recall reading anything 
about that.

Given the recent postings about production of dioxins from uncontrolled 
burning, it may well be that the level of dioxin in the 1800s largely 
stemmed from the incineration that the local populace undertook. It clearly 
wasn't the chemical industry.

cheers
david


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From burnt_paper@hotmail.com Sun, 09 Jan 2000 23:32:35 GMT
Date: Sun, 09 Jan 2000 23:32:35 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distr...

Hi Carl
>Connie,
>
>I would be more interested in knowing about any contamination from the PVC
>pipe now used in many water systems than of the chlorination of the water
>itself.

PVC is long-chain, and essentially insoluble in water. Hence it has no 
toxicity. Vinyl chloride monomer is a good human carcinogen, but there is 
very little of it in PVC, it gets diluted out a lot, and you can detect the 
resulting cancer very easily. VCM gives cholangiocarcinoma in humans, and I 
am not aware in any variation in the rate of this rare human cancer.

>My other concern is the combination of chlorine and organic compounds to 
>form
>triholomethane for example. I don't think that we can just look at free
>chlorine by itself.

I guess you are probably aware that there is a massive ongoing debate around 
this issue. Some people argue that the (potential) cancer risk from tiny 
quantities of chloromethanes are significant. Others, that the public health 
benefits of chlorination vastly outweigh any cancer risk. There is a 
well-founded argument that the carcinogenicity of trichloromethane has a no 
effect level- and that the low levels in water are without significance.

cheers
david

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From burnt_paper@hotmail.com Mon, 10 Jan 2000 00:20:26 GMT
Date: Mon, 10 Jan 2000 00:20:26 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distribution

If I read the abstract below correctly, E coli is inactivated by residual 
chlorine throughout the distribution system. Given that E coli is a 
principal contaminant of sewage (and in turn the water supply system), and 
can be highly pathogenic (eg E coli 0157), this abstract can easily be used 
to make a case for chlorination of water supplies.

I am not sure what to make of the abstract; viruses can be very difficult to 
kill, and (I believe) some clostridia have a spore, again making them very 
difficult to disinfect. I don't know that E coli isn't a much more 
representative bacterial pathogen than the others this abstract measures.

david bell

Payment, P. 1999. <snip>Can J Microbiol 45(10):709-15
Abstract
To evaluate the inactivating power of residual chlorine in a
distribution system, test microorganisms (Escherichia coli,
Clostridium perfringens, bacteriophage phi-X 170, and poliovirus
type 1) were added to drinking water samples obtained from two
water treatment plants and their distribution system. Except for
Escherichia coli, microorganisms remained relatively unaffected in
water from the distribution systems tested.
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From superjicb@email.msn.com Sun, 9 Jan 2000 21:44:20 -0800
Date: Sun, 9 Jan 2000 21:44:20 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] "normal background level"

David,

I daresay that you are unlikely to find anyone on this board that does not
support sound science.  I consider it pure dribble that you even ask me this
question.  I recognize this question as a much over-used tactic to ignore
science and logic by the person who asks it, when they find themselves faced
with something they don't want to hear.  Move on.  Share sound science,
instead of sharing the obvious notion that science should be sound.  Also
remember that because we are discussing science, that these issues are not
always black and white.  Think of your school days when you learned about
hypothesis, theories, proofs and facts. I think that we would all agree that
it is a fact that dioxin is a deadly toxin.  I think that we would all agree
that it is a fact that under certain conditions dioxin is created in
incineration.  I believe I could easily name a level of dioxin that none of
us would be willing to ingest for any advantage, be it cheaper car panels,
or a higher paycheck.   What is in contention is how much dioxin we believe
we can ingest over time before it kills us, and how much we are willing to
risk that we've picked the correct number.   The complication comes in
because our willingness to take on risk is always balanced by expected
rewards.  Environmental advocates see little reward to taking on the risk,
and can be expected to err on the side of caution.  Industries that make
mega bucks off of products that contribute to dioxin can be expected to err
on the side of risk.

> it rapidly became impossible to state
> that the hole was a fabrication or, that CFCs were not plausibly involved.
> This was the basis for incredibly convincing argument.

Glad to see that you are not outright denying that there was a period that
some groups pooh-poohed the need to move away from CFCs. I was there to read
the published reports and they became so strong that at one point I remember
wondering if the issue would go away.  Part of my point was that industry,
scientists and environmental groups all had reason to support CFC
elimination.  When most everyone's motives are in accord, things get done.

> I think you are right about some of the practical problems which you
raised
> about the difficulties of reducing dioxin emission, but for my money, I
> would point out to you that there is considerable lack of consensus about
> the 'safe' level for dioxin. For example, Canada and the UK have an
> Tolerable Daily Intake (for TCDD) 1000 fold bigger than in the US; the WHO
> limit is 100-400 x bigger than the US TDI. The point I am making (without
> taking sides !!) is that there is no clear scientific consensus.

Thank you for acknowledging this distinction.  I'll put my money towards
erring on the side of caution.

> Given the recent postings about production of dioxins from uncontrolled
> burning, it may well be that the level of dioxin in the 1800s largely
> stemmed from the incineration that the local populace undertook. It
clearly
> wasn't the chemical industry.

Why is it clear chemicals were not implicated?

Connie








From burnt_paper@hotmail.com Mon, 10 Jan 2000 05:39:35 GMT
Date: Mon, 10 Jan 2000 05:39:35 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] dioxin web sites

WHO dioxin pages (they lowered the tolerable daily intake)
http://www.who.int/fsf/dioxin/whoinf.htm

Belgian government site on dioxin (and a link to the EU's report on Belgium)
http://dioxin.fgov.be/pa/ena_frame.htm

Australia's estimates of dioxin emission
http://www.environment.gov.au/epg/pubs/pdf/dioxins.pdf
http://www.environment.gov.au/epg/ic.html

david bell



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From ttweed@wildrockies.org Sun, 9 Jan 2000 23:47:18 -0700
Date: Sun, 9 Jan 2000 23:47:18 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] follow-up TCDD cancer potency/TDI history; earliest refer. to
 dixon?

looking through my files for the earliest refer's to dioxin, I discovered
the whole of Dr Commoner's address to the 2nd Citizen's Dioxin Confer. from
which a quote was posted here (about O-Cl's ocurance in nature).  It mainly
is about the controversy & fraud of TCDD's cancer risk.  My post of a few
days ago neglected the pre-Banbury conference portion of the story, and I
recommend Commoner's speech to all.

The landmark '78 Kociba et al. TCDD rodent assay (_Tox & Applied Pharmacol.
46:279-303 -- in which 100 ng/kg/d TCDD caused cancers in almost half the
female rats, doses of 10 and 1 ng/kg/d were also given but I don't know the
results) led to EPA's '85 TDI (estimated "safe" intake) of 0.006 pg/kg/d,
for ambient water standard setting.

[See 1980's  Poland & Glover "A Model for the Mechanism of Action of
2,3,7,8-TCDD', published in the proceedings of the confer. "Estrogens in
the Env.', ed. MacLachlan of NIEHS, which I think was published in _Env
Health Perp's_, NIEHS' journal.  This is an incredible (for 1980, as is the
whole NIEHS sponsored conference) summary of the Ah mode of action of TCDD
(which mechanism is cited by propnents & opponents of weaking the TDI, as
it was by Commoner).  This paper also shows that PAHs, tho binding to Ah,
do not induce enzymes and proteins/do not get carried into the nucleus; but
TCDD and various halogenated analogues to it (ie planar and 3 X 10
angstroms in 2-D size) do.]

Commoner says a Dow scientist challanged the Kociba sudy and EPA's
resulting '85 standard.  The P&P industry's toxicologists borrowed the
microscope slides to look for cellular signs of uncontrolled growth
(cancer), and were split in opinion--resolvced by a vote (not a
conservative aproach!) to reduce the cancer potency by half.

Commoner then says EPA set up a Workgroup chaired by the Reagan AA for OR&D
(Office of Reearchs & Develpmnt.), which came out w/ an external a draft
review of the '85 RA in '87.  They chose to AVERAGE the various cancer risk
estimates -- -industry's and EPA/Kociba et al. (god scientific method!--as
Comoner points ot, one or the other models is right--it's potent or less
potent...).  The Workgroup  withdrew this estimate after external comment
(incl. from Commoner and Tom Webster) and accepted the Kociba derived one;
but finally ended up stating it may be an overestimate of risk and that the
cancer potency was 16 X's less than the '85 estimate ("unencumbered by
factual scinetific analysis", as C. puts it).

These EPA and industry reviews of Kociba led to the '90 Banbury conference
(sponsored by EPA and the Chlorine Institute, but it was industry's PR
spinners who relesed a false claim that there was consensus at the
conference that TCDD's cancer potency-->and other AH mediated effects--was
indeed less potent).  Pick up the story from that _Science_ news article I
cited in my previous post on this (in sum, EPA agreed to review dioxin-like
(TCDD-like) compounds once more, and--w/ fianlly opening the process to
scientific review --ended up essentially confirming the Kociba study,
setting the cancer TDI @ 0.01 pg/kg/d (relaxed from 0.06); but it also
based risk on cumulative exposures and on all the dioxin-like PCDD/F/PCBs,
and on non-cancer effects (as the stiill v. incomplete data allows).

To me, this history shows the critical importance of supporting science and
scientists.  This includes letting them work, accepting their claims as
possible, arguing from that basis, and encouraging openess (which incl's
publication).  Now if only industry's scientists would generally live up to
this standard of openess!
----

Commoner also gives here the earlest refer. I have about the existance of
dioxins or TCDD.  He says 2 Atlanta physicians published in '36 in _Arch
Derm. & Sypholology_ a case study of two Monsanto Anniston AL workers. One,
"O.D., a Negro aged 26 [who] began work in the distillation of chlorinated
diphenyl in April 1930."  Diphenyl is the dioxin backbone--perhaps the
plant was making DDT?  Commoner writes:  The patient had severe chloracne
and even in Dec. '33 "complained of lassitude, loss of apetite and libido."
"His complaint of lassitude was not borne out by anything nore than the
usual temperament of the Negro towards work." [!].  Elsewhere I see the
famous '65 Dow experiment of painting Pennsylvania prisoner's backs w/
dioxins (w/out consent or informed consent).  In between, internal company
(BASF, Monsanto, Dow, Hercules, etc.) dioxin studies, some studying
accidents/explosions from the '40's & '50's) began seeing the light of day
(reluctantly) by the early '70's, perhaps a bit earlier.  Commoner, CEHJ's
Carol van Strum (activist and USFS (Forest Svc)  2,4,5-T aerial victim),
EPA's Bill Sanjour, Dr. Richard Clapp, the VVA (Vietnm Vets Amer.) and
Chicago Media Watch  (Liane Casten), inter alia, have compliled the record
of early industry fraud and cover-ups on dioxin.  Commonly, the exposed
would be moved into non-exposed study groups, and vice-versa, in these
company woker studies.  All these reviews, incl Dr. Commoner's speech, are
published in _Synthesis/Generation--A Magaz. of Green Social Thought_,
Summer '95.

Does anyone have any cites mentioning dioxins bewteen 1936 (or earlier!)
and '65?
---


Casten, Sanjour and elsewhere CCHW's (now CEH&J) Steve Lester (in their
_Everyone's Backyard_:13:3), have also summarized EPA's reaction,
butressing Commoner on the Kociba saga.  V. briefly, EPA in '87 began
considering industry's detoxifying claims.  But in '90 EPA's Cate Jenkins
alerted EPA's Science Adv. Board (SAB) about such fraud by BASF & Monsanto;
SAB advised EPA continue to rely on the animal studies.  EPA then
investigated but dropped a crimminal investigation on the companies.

VP Gore has heard and repeated (Oct '95) that every breath we take has
6-times the # of Cl atoms as before WW2...

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth







From ttweed@wildrockies.org Mon, 10 Jan 2000 00:13:55 -0700
Date: Mon, 10 Jan 2000 00:13:55 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] more on EPA's proposed 300 ppt dioxin standard for sludge

I received the below in reply to a querry about the safety of this proposed
standard for dioxins in sludge. Late it came to me that this is obviously
deliberate attempt  by EPA Admin. Browner to enshrine yet another lax
dioxin standard before releasing as final their Dioxin Reassessment, w/ its
TDI (estim. safe dose) of 0.01 pg.kg/d (for a ligfetime cancer risk of
10E-6, or one/million).  This TDI, we all realize, is 100 to 1,000 times
more stringent than other proposed and existing ones around the
world--plenty of reason for EPA to hold the RA and finaliize as many
orders-of-magnitude too weak dioxin limits as it can get away with.  The
Med Waste Incinerator rule, other incinerator rules, the P&P "Cluster" rule
are all examples of orders of maginutide lax dioxin standards finalized
since the '94 External Review Draft Dioxin Reassessment.  This speaks to me
of infered yet clear economic corporate power and of their money in the
Clinton Admin.

The below goes well beyond my reply to the querry I received, in which I
used the exposure asumptions (eg child's hand-to-mouth behavior) of ATSDR's
current Interim dioxin soil exposure Min. Risk Levels (MRL's, used for
initial screening of contaminated sites, for further action), but
substituted the EPA draft TDI for cancer risk (0.01 pg/kg/d) for ATSDR's
laughably-poorly justified TDI of 1 pg/kg/d.  For ATSDR, back-calculating
from this TDI leads to an action level of 1 ppb (1,000 ppt) dioxin in soil;
using EPA's draft TDI (but same exposure assumptions) it leads to 10 ppt.
Yet EPA wants to set a limit in sludge of 300 ppt!  More pin-head politics
trumping science and public health's prevention principle.

Of course, you can't really assume that exposure to food grown in
dioxinated sludge is identical to exposure from playing in dioxinated soil.
Yet my initial thought is that more dioxin would be tranferred to you in
the sludge->food exposure scenario.  Please make your explicit thoughts
known to EPA (see below, the sludge comment ends 22 Feb., but also let the
Admin. know that we know she is squelching and playing GOd w/ public health
(the Reassessment) and that we will hold her accountable, a/w/a whoever
else is doing so).
---


Date: Sat, 08 Jan 2000 13:54:17 -0500
From: "Caroline G. Snyder" <cgsnyder@post.harvard.edu>
To: ttweed@wildrockies.org
Subject: [Fwd: EPA's proposed 300 ppt dioxin standard for sludge]

--
Caroline G. Snyder   cgsnyder@post.harvard.edu
Date: Thu, 06 Jan 2000 12:17:50 -0500
From: "Caroline G. Snyder" <cgsnyder@post.harvard.edu>
To: Tom Irwin <tirwin@clf.org>
Subject: EPA's proposed 300 ppt dioxin standard for sludge

In 1992, the Wisconsin Department of Health (WDOH) did a human cancer
risk assessment for dioxin TEQ in agricultural soils.  Using realistic
and conservative assumptions, WDOH concluded that dioxin levels of 1.2
ppt in agricultural soil ( other than grazing pastures) and 0.19 ppt in
soil of grazing pastures is protective of human health.  Current
Wisconsin sludge regulations specify a 0.5 ppt soil limit for pastures
and a 1.2 ppt dioxin limit in other agricultural soil.

On December 23, EPA's Office of Water proposed a limit of 300 ppt of
dioxin TEQ for sludge that is land applied.

EPA's risk assessment addresses only the human cancer risks;  it ignores
the many other serious health risks from dioxin, especially to children,
and it does not address the dioxin risks to live stock or wildlife.  The
risk assessment appears to use unrealistic and non-conservative
assumptions very similar to those that were used for the Round One risk
assessment that led to the 503's ( Cf. Harrison et al, Case for
Caution).

For example, EPA's Office of Water uses deterministic point estimates
for input variables, ignores synergistic effect on all levels,
exaggerates dilution factors, underestimates erosion and dust exposure,
underestimates surface water impact, greatly underestimates the
consumption of beef and diary products produced on sludged pastures and
underestimates the amount of soil/sludge ingested by grazing animals.
Five singificant exposure pathways that impact human health, live stock,
or wildlife,  are not addressed because of insufficient data.  Much of
the recent dioxin literature appears to have been ignored.

We urge you to write to EPA's Office of Water objecting to this proposed
rule which will futher endanger human health, agricultural soil, live
stock and the environment from land application of sludge.  Such high
levels of a potent, persistent, and bioaccumulative poison  should not
be spread deliberately on our land.

The deadline for comments in midnight, February 22..

Mail:  Part 503 Sewage Sludge Use of Disposal Rule; Docket Number
W-99-18, Comment Clerk
       Water Docket MC-4101
       US Environmental Protection Agency
       401 M Street, SW
       Washington, DC 20046

For up-to-date information on dioxin's adverse
health effects and for policy recommendations, see CCHW's recent repport
at  www. essential org/cchw/campaign/policy.html

Caroline Snyder, President    Citizens for a Future New Hampshire
--
Caroline G. Snyder   cgsnyder@post.harvard.edu

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth







From superjicb@email.msn.com Mon, 10 Jan 2000 09:22:03 -0800
Date: Mon, 10 Jan 2000 09:22:03 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Reply

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David,
Your comment:

> One of the interesting things is that erring on the side of caution =
can have its costs. So currently, the US EPA estimates daily intake of =
dioxin TEQs as 1-4 ng/kg, or 100-400 times greater than the EPA =
recommended intake. It is not clear how one would get the level of =
dioxin TEQ intake down by 400 fold; it would certainly be an expensive =
undertaking. Some estimates are that it would cost in excess of the US =
GNP to reduce dioxin intakes to the US EPA=20
recommended levels; clearly you would only want to spend that money if =
there were to be a tangible benefit.

My reply:

One of the interesting things is that erring on the side of risk can =
have is costs, both to human health, shorter life spans, and to the =
economy in the form of high medical bills, lost productivity, etc.  I =
cannot comment on the validity of the EPAs numbers but plain old common =
sense tells me that here we are not even talking about erring on the =
side of risk.  If scientists already think our dioxin intake is too =
high, then we are talking about blatent disregard. This only makes it =
more urgent that we move quickly to do what we can to stop from =
increasing dioxin levels even further.  The answer is not to throw up =
our hands and give up. =20


Your comment:
> > > Given the recent postings about production of dioxins from =
uncontrolled burning, it may well be that the level of dioxin in the =
1800s largely stemmed from the incineration that the local populace =
undertook. It clearly wasn't the chemical industry.

 My initial reply:
> >Why is it clear chemicals were not implicated?

 Your reply:
> There was next to no organochlorine chemical industry in the late =
1800s, and=20
> precious little in America. Compare with hundreds of millions of tons =
of=20
> organochlorines produced in the 60s; as far as I am aware, there =
wasn't the=20
> technology to make, transport or a market to sell a million tons of=20
> organochlorine compound in the 1800s. So where did the environmental =
dioxin=20
> production come from in the 1800s? It still amounted to 10% of current =

> levels. I guess I can only think of uncontrolled burning; all =
suggestions=20
> welcome.

My reply:

I can come up with a reason other than uncontrolled burning that would =
implicate chlorine.  When we talked about dioxin in the late 1800s it =
was related to the Beaver Lake dioxin in sludge study that you brought =
to our attention.  We all know chemical pulping occurs on large bodies =
of water.  I think we both agreed that the mid 1950s dioxin =
contamination of this lake likely came from chlorine bleaching of pulp.  =
 What is in contention is what occurred early on.  Successful chemical =
pulping began in about 1851 and to the best of my knowledge, pulp was =
bleached with chlorine even before chemical pulping became the standard. =
 In the early 1800s British scientists already knew how to produce =
chlorine electrochemically, but because electricity was so expensive =
electrochemical chlorine production did not occur until the 1900s, and =
in the 1800s commercial chloirne was produced by oxidation of HCl with =
manganese dioxide or air.  I expect we'd all agree that early pulping =
and bleaching was done with nearly total disregard for the environment =
(not intentional disregard, but because industry was likely unaware of =
the problem brewing).   I don't know the size of Beaver Lake, or how =
many if any mills it supported, or if there was a chlorine plant on site =
to support pulp bleaching, but logic suggests the whole thing is related =
to pulp bleaching.  You brought up this study as evidence of some point. =
 Would you please let us know what industry was on this lake and when, =
so we can draw some intelligent conclusion from the data?

Connie

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<BODY bgColor=3D#fffff0>
<DIV><FONT face=3DArial size=3D2>David,
<P class=3DMsoNormal>Your comment:</P>
<P class=3DMsoNormal>&gt; One of the interesting things is that erring =
on the side=20
of caution can have its costs. So currently, the US EPA estimates daily =
intake=20
of dioxin TEQs as 1-4 ng/kg, or 100-400 times greater than the EPA =
recommended=20
intake. It is not clear how one would get the level of dioxin TEQ intake =
down by=20
400 fold; it would certainly be an expensive undertaking. Some estimates =
are=20
that it would cost in excess of the US GNP to reduce dioxin intakes to =
the US=20
EPA <BR>recommended levels; clearly you would only want to spend that =
money if=20
there were to be a tangible benefit.</P>
<P class=3DMsoNormal>My reply:</P>
<P class=3DMsoNormal>One of the interesting things is that erring on the =
side of=20
risk can have is costs, both to human health, shorter life spans, and to =
the=20
economy in the form of high medical bills, lost productivity, etc.&nbsp; =
I=20
cannot comment on the validity of the EPAs numbers but plain old common =
sense=20
tells me that here we are not even talking about erring on the side of=20
risk.&nbsp; If scientists already think our dioxin intake is too high, =
then we=20
are talking about blatent disregard.&nbsp;This only makes it more urgent =
that we=20
move quickly to do what we can to stop from increasing dioxin levels =
even=20
further.&nbsp; The answer is not to throw up our hands and give =
up.&nbsp; </P>
<P class=3DMsoNormal><BR>Your comment:<BR>&gt; &gt; &gt; Given the =
recent postings=20
about production of dioxins from uncontrolled burning, it may well be =
that the=20
level of dioxin in the 1800s largely stemmed from the incineration that =
the=20
local populace undertook. It clearly wasn't the chemical industry.</P>
<P class=3DMsoNormal>&nbsp;My initial reply:<BR>&gt; &gt;Why is it clear =
chemicals=20
were not implicated?</P>
<P class=3DMsoNormal>&nbsp;Your reply:<BR>&gt; There was next to no =
organochlorine=20
chemical industry in the late 1800s, and <BR>&gt; precious little in =
America.=20
Compare with hundreds of millions of tons of <BR>&gt; organochlorines =
produced=20
in the 60s; as far as I am aware, there wasn't the <BR>&gt; technology =
to make,=20
transport or a market to sell a million tons of <BR>&gt; organochlorine =
compound=20
in the 1800s. So where did the environmental dioxin <BR>&gt; production =
come=20
from in the 1800s? It still amounted to 10% of current <BR>&gt; levels. =
I guess=20
I can only think of uncontrolled burning; all suggestions <BR>&gt; =
welcome.</P>
<P class=3DMsoNormal>My reply:</P>
<P class=3DMsoNormal>I can come up with a reason other than uncontrolled =
burning=20
that would implicate chlorine.&nbsp; When we talked about dioxin in the =
late=20
1800s it was related to the Beaver Lake dioxin in sludge study that you =
brought=20
to our attention.&nbsp; We all know chemical pulping occurs on large =
bodies of=20
water.<SPAN style=3D"mso-spacerun: yes">&nbsp; </SPAN>I think we both =
agreed that=20
the mid 1950s dioxin contamination of this lake likely came from =
chlorine=20
bleaching of pulp.&nbsp;&nbsp; What is in contention is what occurred =
early=20
on.&nbsp; Successful chemical pulping began in about 1851 and to the =
best of my=20
knowledge, pulp was bleached with chlorine even before chemical pulping =
became=20
the standard.<SPAN style=3D"mso-spacerun: yes">&nbsp; In the early 1800s =
British=20
scientists already knew how to produce chlorine electrochemically, but =
because=20
electricity was so expensive electrochemical chlorine production did not =
occur=20
until the 1900s, and in the 1800s commercial chloirne was produced by =
oxidation=20
of HCl with manganese dioxide or air.&nbsp; I expect we'd all agree that =

</SPAN>early pulping and bleaching was done with nearly total disregard =
for the=20
environment (not intentional disregard, but because industry was likely =
unaware=20
of the problem brewing). <SPAN style=3D"mso-spacerun: =
yes">&nbsp;&nbsp;I</SPAN>=20
don't know the size of Beaver Lake, or how many if any mills it =
supported, or if=20
there was a chlorine plant on site to support pulp bleaching, but logic =
suggests=20
the whole thing is related to pulp bleaching.&nbsp; You brought up this =
study as=20
evidence of some point.&nbsp; Would you please let us know what industry =
was on=20
this lake and when, so we can draw some intelligent conclusion from the=20
data?</P><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">Connie</SPAN></FONT></DIV></BODY></HTML>

------=_NextPart_000_0005_01BF5B4C.28327220--







From burnt_paper@hotmail.com Mon, 10 Jan 2000 18:02:30 GMT
Date: Mon, 10 Jan 2000 18:02:30 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] Reply

Dear Connie

I think your suggestion that industry should be able to horse-trade with 
frank toxicity is both vile and odious. I don't see any place for any horse 
trading with industry in the regulatory process, nor for finding acute 
toxicity to be acceptable; risk assessment should protect human health. Any 
discussion about acceptable levels starts at a level below toxicity to 
humans.

><Snip>I cannot comment on the validity of the EPAs numbers but plain >old 
>common sense tells me that here we are not even talking about >erring on 
>the side of risk.  If scientists already think our dioxin >intake is too 
>high, then we are talking about blatent disregard

The EPA's own Science Advisory Board rejected the conclusions of chapter 8 
of the 1994 dioxin assessment, and their sole remit was whether the chapter 
was scientifically sound (Science Advisory Board. 1995. An SAB Report: A 
Second Look at Dioxin. Review of the Office of Research and Development’s 
Reassessment of Dioxin and Dioxin-Like Compounds by the Dioxin Reassessment 
Review Committee.). The US is unique in having a TDI for dioxin 100 times 
lower than the WHO, or Canada, or the European Union.

cheers
david



______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com






From Jon.Campbell@MetraTech.com Mon, 10 Jan 2000 13:30:29 -0500
Date: Mon, 10 Jan 2000 13:30:29 -0500
From: Jon Campbell Jon.Campbell@MetraTech.com
Subject: [Dioxin-l] Reply

Risk assessment is not protective of human or environmental health. Use =
of
the Precautionary Principle is the only way we will get ourselves out =
of the
industrial-generated mess in which we find ourselves today.

For a frank explanation of the Precautionary Principle and why risk
assessment is not protective, see Rachel's Weekly:

#586 The Precautionary Principle, 19-Feb-1998
#519 Ethical Hazards of Risk Assessment, 07-Nov-1996

and for its application (or lack thereof) see:

#541 - Bad Decisions Again And Again, 10-Apr-97 =20
#540 - History of Precaution, Part 2, 03-Apr-97 =20
#539 - History of Precaution -- Part 1, 27-Mar-97

Jon =20

-----Original Message-----
From: david bell [mailto:burnt_paper@hotmail.com]
Sent: Monday, January 10, 2000 1:03 PM
To: superjicb@email.msn.com; dioxin-l@lists.essential.org
Subject: Re: [Dioxin-l] Reply


Dear Connie

I think your suggestion that industry should be able to horse-trade =
with=20
frank toxicity is both vile and odious. I don't see any place for any =
horse=20
trading with industry in the regulatory process, nor for finding acute=20
toxicity to be acceptable; risk assessment should protect human health. =
Any=20
discussion about acceptable levels starts at a level below toxicity to=20
humans.

><Snip>I cannot comment on the validity of the EPAs numbers but plain =
>old=20
>common sense tells me that here we are not even talking about >erring =
on=20
>the side of risk.  If scientists already think our dioxin >intake is =
too=20
>high, then we are talking about blatent disregard

The EPA's own Science Advisory Board rejected the conclusions of =
chapter 8=20
of the 1994 dioxin assessment, and their sole remit was whether the =
chapter=20
was scientifically sound (Science Advisory Board. 1995. An SAB Report: =
A=20
Second Look at Dioxin. Review of the Office of Research and =
Development=92s=20
Reassessment of Dioxin and Dioxin-Like Compounds by the Dioxin =
Reassessment=20
Review Committee.). The US is unique in having a TDI for dioxin 100 =
times=20
lower than the WHO, or Canada, or the European Union.

cheers
david



______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com



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Dioxin-l@lists.essential.org
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From superjicb@email.msn.com Mon, 10 Jan 2000 14:06:06 -0800
Date: Mon, 10 Jan 2000 14:06:06 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Reply

David,

Who are you?  What ideas do you represent?  Why are we not communicating?
One minute I think you are indicating to us that dioxin levels are so high
that there is nothing we can do about dioxin to reduce it to acceptable
levels, and that anything we did would therefore just be a waste of money.
When I let you know that I would consider this solution platent disregard
for human health, and that we should stop producing dioxin immediately, you
come back and call my suggestion vile and odious.  Is this a bit of English
comedy or are American and English different languages?  Or what?  I am
totally confused.

Connie

> Dear Connie
>
> I think your suggestion that industry should be able to horse-trade with
> frank toxicity is both vile and odious. I don't see any place for any
horse
> trading with industry in the regulatory process, nor for finding acute
> toxicity to be acceptable; risk assessment should protect human health.
Any
> discussion about acceptable levels starts at a level below toxicity to
> humans.
>
> ><Snip>I cannot comment on the validity of the EPAs numbers but plain >old
> >common sense tells me that here we are not even talking about >erring on
> >the side of risk.  If scientists already think our dioxin >intake is too
> >high, then we are talking about blatent disregard
>
> The EPA's own Science Advisory Board rejected the conclusions of chapter 8
> of the 1994 dioxin assessment, and their sole remit was whether the
chapter
> was scientifically sound (Science Advisory Board. 1995. An SAB Report: A
> Second Look at Dioxin. Review of the Office of Research and Development's
> Reassessment of Dioxin and Dioxin-Like Compounds by the Dioxin
Reassessment
> Review Committee.). The US is unique in having a TDI for dioxin 100 times
> lower than the WHO, or Canada, or the European Union.
>
> cheers
> david
>
>
>
> ______________________________________________________
> Get Your Private, Free Email at http://www.hotmail.com
>
>
>
> _______________________________________________
> Dioxin-l mailing list
> Dioxin-l@lists.essential.org
> http://lists.essential.org/mailman/listinfo/dioxin-l







From Ralph@tcpublications.freeserve.co.uk Mon, 10 Jan 2000 21:22:55 +0000
Date: Mon, 10 Jan 2000 21:22:55 +0000
From: Ralph Ryder Ralph@tcpublications.freeserve.co.uk
Subject: [Dioxin-l] Reply

>    > There was next to no organochlorine chemical industry in the late 
>    1800s, and 
>    > precious little in America. Compare with hundreds of millions of 
>    tons of 
>    > organochlorines produced in the 60s; as far as I am aware, there 
>    wasn't the 
>    > technology to make, transport or a market to sell a million tons 
>    of 
>    > organochlorine compound in the 1800s. So where did the 
>    environmental dioxin 
>    > production come from in the 1800s? It still amounted to 10% of 
>    current 
>    > levels. I guess I can only think of uncontrolled burning; all 
>    suggestions 
>    > welcome.

Brief background info FYI: 
Herbert Henry Dow arrived in Midland in August 1890. He knew men had
been pumping brine from the underground sea and evaporating it by heat
from their waste lumber to make salt for dozens of years. 
Dow knew that Midlands brine was rich in bromine and had devised a way
to separate this from the brine deposits using electricity.

He founded the Midland Chemical Company and expanded this when he
discovered the brine contained more chlorine than bromine. An hour after
throwing the switch in his new chlorine plant it blew up. 
He refined his plans and with the backing of 57 investors 6 months later
founded the Dow Chemical company in the spring of 1897. Bleaching powder
was in high demand by the textile and cotton mills. Explosions continued
at the plant and problems were to be found throughout the industry with
some workers in the bleach chamber of Hooker Electrochemical Company
(Niagara Falls, New York) quitting before  the timekeeper had made out
their cards.

Dow chemical dumped its wastes out of the back door into the
conveniently located Tittabawassee River. The Indians called it the
'Shinning river.' It soon lost its lustre.

I have posted this recommendation before but will unashamedly do so
again. 'Elements of Risk'
The Chemical Industry and Its Threat to America. 
Cathy Trost, Times Books  1984 ISBN 0-8129-1114-8

cheers

Ralph

 
**************************************************************** 
Ralph Ryder
Communities Against Toxics
PO Box 29
Ellesmere Port
Cheshire UK
CH66 3TX
Email ralph@tcpublications.freeserve.co.uk
Tel/Fax 0151 339 5473
****************************************************************





From dhenshel@indiana.edu Mon, 10 Jan 2000 19:49:41 -0500
Date: Mon, 10 Jan 2000 19:49:41 -0500
From: Henshel, Diane S. dhenshel@indiana.edu
Subject: [Dioxin-l] Reply

It seems to me the argument below could be settled with congener analysis.
Since incineration produces primarily the PCDFs and relatively little TCDD,
it should have a clear chemical signature very distinct from the chemical
signature released by kraft pulp bleaching processes, in which there is a
high percentage of TCDD contamination.
Has anyone got the congener data?

Your comment:
> > > Given the recent postings about production of dioxins from
uncontrolled burning, it may well be that the level of dioxin in the
1800s largely stemmed from the incineration that the local populace
undertook. It clearly wasn't the chemical industry.

 My initial reply:
> >Why is it clear chemicals were not implicated?

 Your reply:
> There was next to no organochlorine chemical industry in the late
1800s, and 
> precious little in America. Compare with hundreds of millions of tons
of 
> organochlorines produced in the 60s; as far as I am aware, there
wasn't the 
> technology to make, transport or a market to sell a million tons of 
> organochlorine compound in the 1800s. So where did the environmental
dioxin 
> production come from in the 1800s? It still amounted to 10% of current

> levels. I guess I can only think of uncontrolled burning; all
suggestions 
> welcome.

My reply:

I can come up with a reason other than uncontrolled burning that would
implicate chlorine.  When we talked about dioxin in the late 1800s it
was related to the Beaver Lake dioxin in sludge study that you brought
to our attention.  We all know chemical pulping occurs on large bodies
of water.  I think we both agreed that the mid 1950s dioxin
contamination of this lake likely came from chlorine bleaching of pulp.
What is in contention is what occurred early on.  Successful chemical
pulping began in about 1851 and to the best of my knowledge, pulp was
bleached with chlorine even before chemical pulping became the standard.
In the early 1800s British scientists already knew how to produce
chlorine electrochemically, but because electricity was so expensive
electrochemical chlorine production did not occur until the 1900s, and
in the 1800s commercial chloirne was produced by oxidation of HCl with
manganese dioxide or air.  I expect we'd all agree that early pulping
and bleaching was done with nearly total disregard for the environment
(not intentional disregard, but because industry was likely unaware of
the problem brewing).   I don't know the size of Beaver Lake, or how
many if any mills it supported, or if there was a chlorine plant on site
to support pulp bleaching, but logic suggests the whole thing is related
to pulp bleaching.  You brought up this study as evidence of some point.
Would you please let us know what industry was on this lake and when, so
we can draw some intelligent conclusion from the data?

Connie





From superjicb@email.msn.com Mon, 10 Jan 2000 20:02:04 -0800
Date: Mon, 10 Jan 2000 20:02:04 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Reply

Diane,

I don't have the analysis.  Dave is the guy with information on Beaver Lake.
I just didn't think we could draw any conclusions without more information.

> Connie







From ttweed@wildrockies.org Mon, 10 Jan 2000 22:30:33 -0700
Date: Mon, 10 Jan 2000 22:30:33 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] follow-up TCDD cancer potency/TDI history

From: "Henshel, Diane S." <dhenshel@indiana.edu> Re:
>>This paper also shows that PAHs, tho binding to Ah,
>>  do not induce enzymes and proteins/do not get carried into the nucleus;

>PAHS (once bound to the Ah receptor) most certainly do translocate to the
>nucleus and induce enzymes, albeit not with the same potency as TCDD.  There
>is plenty of both enzyme induction data and mRNA increase data to support
>this, in multiple species and in studies conducted by more scientists now
>then I could list off the top of my head, well above a dozen or so.
>Benzo-a-pyrene (a PAH) is commonly used as one of the standards against
>which other EROD (a marker of P4501A enzyme activity) inducing-activity is
>compared.
----

I in-accurately summarized the '80 Poland & Glover paper 'A Model for the
Mechanism of Action of 2,3,7,8-TCDD'.  On p. 338 they say:

"We do not understand why nonhalogenated agonists for the receptor, eg PAHs
and b-napthaflavone do not do not produce the characteristic spectrum of
toxic responses produced by TCDD and its congeners. ...The ... [may] ...
binds differently to the nuclear  sites ... Alternately ... sustained
occupation of the receptor and the long biological half-lives of the
halogenated aromatic compounds ... In support of this latter possibility we
have found that MC [a PAH] and b-napthaflavone will produce thymic
involution, a response characteristic o TCDD toxicity."

Sorry about the mistatement.  Another cause was the author's distinction of
"true induction, i.e. de novo protein synthesis.", tho even there (p. 335)
they name several hepatic enzymes that both  MC and TCDD induce.  This
paper is pretty amazing--this and much more that was known about the
mechanism of toxicity, by 1980!

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth







From ttweed@wildrockies.org Mon, 10 Jan 2000 21:57:39 -0700
Date: Mon, 10 Jan 2000 21:57:39 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] NTP solicits comments for scope of ED peer review

[Federal Register: January 6, 2000 (Volume 65, Number 4)]
[Notices]
[Page 784-787]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr06ja00-51]

-----------------------------------------------------------------------

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Public Health service

National Institute of Environmental Health Sciences, NIH;
National Toxicology Program; Solicitation of Comments on Proposed Peer
Review of Low-Dose Issues for Endocrine Disruptors

SUMMARY: NTP is soliciting comments on the planned scope and process
for a proposed peer review of studies bearing on the question of
whether endocrine disruptors may cause effects at doses lower than are
tested using standard toxicological testing procedures. Nominations for
peer reviewers, as well as nominations for studies to be reviewed, are
also being solicited. Results from the peer review will help the U.S.
Environmental Protection Agency (a member agency of the NTP) and, in
particular the EPA's Endocrine Disruptor Screening Program, determine
how to address low-dose questions in endocrine disruptor screening,
testing, and hazard assessment.

Background

    The U.S. Environmental Protection Agency (EPA) is implementing an
Endocrine Disruptor Screening Program as required by the Food Quality
Protection Act of 1996 (See 63 FR 71542-71568, Dec. 28, 1998). The EPA
is in the process of choosing appropriate assays to use in this
screening program and is also developing standardized, validated
protocols for these assays. A critical aspect of protocol development
is dose-setting. In recent years, there have been suggestions that
hormonally active agents may cause effects at doses lower than those
normally selected for toxicological testing. A review of the issue can
be found in the National Academy of Science's recently-released report
Hormonally Active Agents in the Environment (NRC [National Research
Council]. 1999. Washington, DC: National Academy Press, pp. 103-111).
    The EPA has asked the National Toxicology Program to establish an
independent panel of scientists to review the evidence related to low-
dose effects and consider their implications for the development,
validation, and interpretation of test protocols. If this Panel
concludes that significant effects at low doses occur and that the
standard dose-setting paradigm is inadequate to detect such effects,
the EPA intends to pursue in a separate forum the question of how to
test for such effects, including endpoints to be tested, dose-setting
protocols and appropriate test methods. If the Panel believes the
current data to be inconclusive, it will be asked to describe specific
research that would resolve the ambiguities.

Proposed Scope and Process for the review

A. Scope of the Review

    Analysis will focus on interpretation of the major data sets
showing or refuting effects at low doses. ``Low doses'' are defined for
the purposes of discussion as ``doses below the currently accepted No
Observed Adverse Effect Level for that substance''. The intent is to
evaluate the presence or absence of low-dose effects in specific
studies, then evaluate the likelihood and significance of these and/or
other potential low-dose effects to humans.
    The main topic to be addressed is evidence for defining the shape
of the dose/response curves for endocrine-active substances in the low-
dos region.
    The review is expected to examine all evidence, including such
things as relevant pharmacokinetic and mechanistic information, which
may have a bearing on the low-dose issue. In order to come to
disclosure on the central issue of whether there are sufficient grounds
to change the traditional dose-setting paradigm for endocrine-active
substances, it will not be possible to go into the details of non-
central issues. Issues which may enter the discussion but which are not
the central forcus and will not get exhaustive review include:

    --existence of inverted U-shaped dose/response curves as a general
phenomenon in toxicology;
    --completeness of the list of endpoints examined in two-generation
toxicity tests;
    --definition of ``adversity''.

B. Selection of Studies for Review

    Given the breadth of the scope, many studies are likely to be
considered relevant to the discussion. NTP proposes to divide studies
into two categories: those which provide background information and
those which hare critical to the resolution of the issue. Hard copies
of both the background information and critical studies will be
provided to the Panel in advance of the Peer Review Meeting. For the
critical studies, principal investigators will be invited for in-depth
discussions with the Panel, and the data sets from these critical
studies will be subjected to independent analyses by the panel. NTP
anticipates that approximately 10 to 12 studies might be designated
critical.

C. Criteria for Selection of Studies for Review

    Studies which provide direct evidence for the presence of effects
related to the endocrine system at doses below the No Observed Adverse
Effect Level will generally be considered critical. Studies which
provide direct evidence against such effects at similar doses for the
same chemical will also generally be considered critical. Studies which
provide direct evidence for endocrine-related effects for chemicals for
which NOAELs have not been established will generally be considered
critical if there is reason to believe that normal procedures for
establishing a NOAEL would set NOAELs at a higher level than those
indicated by the study in question, as long as the difference in
putative NOAELs would be due to dose/response considerations rather
than to definitions of adversity or selection of endpoints for
observation. Studies which provide direct evidence against effects at
similar doses from chemicals for which such claims have been made will
also generally be considered critical.
    Pharmacokinetic and mechanistic studies which provide insight into
the plausibility or relevance of effects established in the direct
studies may be either critical or background information depending on
how closely they address low-dose issues.
    Studies of other endocrine effects caused by a substance for which
a low-dose endocrine effect is established will be considered
background information unless mechanistic information establishes a
relevant relationship to the low-dose effect.
    In general, potency per se, is not a central issue. Studies which
show effects at low doses but whose central issue in setting a NOAEL is
either the definition of adversity or the completeness of the list of
endpoints for which observations are made will not be considered
relevant to the dose/response issues that this peer review will
address.
    For background information, well-written reviews will be preferred
over individual studies. Only studies or reviews which have been
published in standard, peer-reviewed scientific journals or books will
be considered.

[[Page 785]]

    Critical studies must be accepted for publication in a standard,
peer-reviewed scientific journal or book by April 1, 2000. Studies
presented at scientific meetings but not formally accepted for
publication in a peer-reviewed journal will not be accepted.
    Raw data for critical studies must be available for the Panel to
review and analyze. ``Raw data'' includes data on individual laboratory
animals, prior to aggregation by statistical or other methods. Data
reported under Good Laboratory Practices, for example, will generally
be considered ``raw data''.

D. Selection Procedure

    An NTP interagency workshop organizing committee will choose the
studies to be considered by the Panel.
    NTP recognizes that the date of acceptance for publication cannot
be predicted with accuracy. Similarly, co-operation by principal
investigators to include a study in this review cannot be guaranteed.
For planning purposes, it may become necessary to designate certain
studies as ``likely to be critical'' before April 1 and to treat them
as if they will be examined at the Panel meeting. However, the criteria
will be applied on April 1.

E. Preliminary List of Published Studies To Be Considered by the Low-
Dose Peer Review Panel

    The NTP has compiled the attached preliminary list of relevant
studies and invites public comment on the list.

F. Peer Review Panel Members

    A panel of 16 to 20 members is anticipated. NTP is soliciting
nominations for the Panel from the public. (See Guidelines for
Submission of Comments below). Kinds of expertise that are likely to be
relevant include reproductive biology (male and female, whole animal
and cellular), endocrinology, pharmacology, statistical data analysis,
and dose/response modeling. Expertise need not be limited to these
areas, nor will these areas necessarily all be included on the Panel.
NTP will try to ensure an appropriate breadth of expertise across the
Panel. If there are particular kinds of expertise that you feel the
Panel should include, please provide a justification in your comments,
especially if the expertise is not covered in the list above.
    Nominations should be accompanied by complete contact information,
including name, address, institutional affiliation, telephone number,
and e-mail address. Where possible, a Web page address for research
interests and/or curriculum vitae should be included. To avoid the
potential for candidates being contacted by a large number of
nominators, candidates need not be contacted prior to nomination. NTP
will solicit curricula vitae and interest in participation at an
appropriate time.

G. Criteria for Selection of Panel Members

    Expertise in a scientific field relevant to the low-dose issue is
required.
    Investigators associated with critical studies will not be
considered for the Panel. Principal investigators (or their designated
co-authors) for critical studies will be asked to present their data
and be available for discussion at the Peer Review Panel meeting, but
will not be asked to be part of the Panel itself.

H. Selection Procedure

    Panelists will be chosen after critical studies have been selected.
An NTP interagency organizing committee will select panel members
considering all nominations received from the public as well as
nominations developed internally. All nominees will be contacted for
interest and availability, and curricula vitae will be solicited from
the nominees. Selection will be based on the CVs and accompanying
information such as statements of research interest. Official
invitations to participate will be sent out in approximately April of
2000. The final list of Peer Review panel members will be available to
the public through the Endocrine Disruptor Screening Program's Interent
Web site (http://www.epa.gov/scinpoly/oscpendo/index.htm). Panel
members will be paid as consultants, and candidates will be required to
disclose potential conflicts of interest.

I. Subcommittee Structure

    NTP proposes to have Subcommittees of the Peer Review Panel examine
specific aspects of the low-dose issue. Subcommittee topics will be
determined after studies for review have been selected. Topics that may
be appropriate for Subcommittees include:
    <bullet> Data Analysis and Statistics
    <bullet> Pharmacokinetics, Receptor Binding, and Modeling
    <bullet> Effects on Males
    <bullet> Effects on Females
    Comments on the appropriateness of having Subcommittees, and of the
specific topics suggested, are welcome.

Approximate Schedule for the Review

    A meeting of the Peer Review Panel is tentatively planned for late
July 2000 in the Research Triangle Park, NC area. The entire peer
review panel meeting will be open to the public, limited only by space
available. Details of the meeting location, dates, and times will be
announced at a later time.
    In order to meet this deadline, designation of critical studies
will take place in March, with Panel selection to begin in the March/
April time frame.
    Between May and late June, the data analysis subcommittee will be
asked to review the data on critical studies. Investigators may be
asked to run analyses of their own data according to the specifications
of the Data Analysis Subcommittee. Approximately four weeks before the
Peer Review, this Subcommittee will have the opportunity to meet with
the investigators by conference call (or, if necessary, at a central
location) to ask questions and obtain additional data that might be
needed in preparation for the Panel meeting. The findings of the Data
Analysis Subcommittee will be made available to the full Peer Review
Panel for discussion at the meeting.
    On the first day of the Peer Review Meeting, presentation from
principal investigators for the critical studies will be heard by the
entire Panel. Also, the Data Analysis and Statistics Subcommittee will
present its analysis of the data to the remainder of the Low-Dose
Panel. Principal investigators of the critical studies will be
available for comment.
    On the second day, the remaining Subcommittee will meet separately
for discussion. Members of the Data Analysis and Statistics
Subcommittee will be asked to split up between the remaining
subcommittees.
    On the third day, the entire Panel will reconvene as a group to
discuss the deliberations of each of the Panels and to integrate the
separate aspects into a report.
    Each of the Subcommittees, as well as the full Panel, will produce
a written Report following the meeting, documenting the discussions and
explaining reasons for the scientific judgments made. These reports
will be submitted for publication in an appropriate peer-reviewed
scientific journal. Reports will also be made on the NTP and EPA
(Endocrine Disruptor Screening Program) Web sites.

Public Input Solicited

    As described above, the NTP solicits comments on the scope and
process for the review; comments on the NTP preliminary list of studies
for review; the nomination of studies to be considered for review; and
the nomination of peer review panel members. Comments, identified by
docket control number OPPTS-42208A,

[[Page 786]]

must be received on or before February 22, 2000.

Guidelines for Submission of Public Comments

    EPA will manage the record-keeping aspects of the Peer Review as
part of the Endocrine Disruptor Screening Program.
    You man obtain electronic copies of this document, and certain
other related documents that might be available electronically, from
the EPA Internet Home Page at http://www.epa.gov/. To access this
document, on the Home Page select ``Laws and Regulations'' and then
look up the entry for this document under the ``Federal Register--
Environmental Documents.'' You can also go directly to the Federal
Register listings at http://www.epa.gov/fedrgstr/.
    For general information about the Endrocrine Disruptor Screening
Program go to http://www.epa.gov/scipoly/oscpendo/index.htm.
    The EPA has established an official record for this action under
docket control number OPPTS-42208A. The official record consists of the
documents specifically referenced in this action, any public comments
received during an applicable comment period, and other information
related to this action. This official record includes the documents
that are physically located in the docket, as well as the documents
that are referenced in those documents. The public version of the
official record does not include any information claimed as CBI. The
public version of the official record, which includes printed, paper
versions of any electronic comments submitted during an applicable
comment period, is available for inspection in the TSCA Nonconfidential
Information Center, North East Mall Rm. B-607, Waterside Mall, 401 M
St., SW, Washington, DC. The Center is open from noon to 4 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
Center is (202) 260-7099.
    You may submit comments through the mail, in person, or
electronically. To ensure proper receipt by EPA, it is imperative that
you identify docket control number OPPTS-42208A in the subject line on
the first page of your response.
    1. By mail. Submit your comments to: Document Control Office
(7407), Office of Pollution Prevention and Toxics (OPPT), Environmental
Protection Agency, 401 M St., SW, Washington, DC 20460.
    2. In person or by courier. Deliver your comments to: OPPT Document
Control Office (DCO) in East Tower Rm. G-099, Waterside Mall, 401 M St.
SW, Washington, DC. The DCO is open from 8 a.m. to 4 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
DCO is (202) 260-7093.
    3. Electronically. You may submit your comments electronically by
e-mail to: ``oppt.ncic@epa.gov,'' or mail your computer disk to the
address identified above. Do not submit any information that you
consider to be CBI. Electronic comments may be submitted in WordPerfect
6.1/8.0 or as an ASCII file avoiding the use of special characters and
any form of encryption. Comments and data will also be accepted on
standard disks in WordPerfect 6.1/8.0 or ASCII file format. All
comments in electronic form must be identified by docket control number
OPPTS-42208A. Electronic comments may also be filed online at many
Federal Depository Libraries.
    Do not submit any information that you consider to be Confidential
Business Information. If you believe that relevant information will be
overlooked because of this restriction, please consult the person
identified under FOR FURTHER INFORMATION CONTACT.

FOR FURTHER INFORMATION CONTACT:
James P. Kariya, Office of Science Coordination and Policy (7203),
Office of Prevention, Pesticides, and Toxic Substances, Environmental
Protection Agency, 401 M St. SW, Washington, DC 20460; telephone
number: (202) 260-2916; e-mail address: kariya.jim@epa.gov.

    Dated: December 28, 1999.
Kenneth Olden,
Director, National Toxicology Program, Department of Health and Human
Services.

Attachment--Preliminary List of Published Studies to Be Considered
by the Low-dose Peer Review Panel

    The NTP has compiled a preliminary list of relevant studies. The
public is invited to comment on this list; suggestions for
additions, deletions, and substitutions may be submitted. (See
Section of this FR announcement on Guidelines for Submission of
Public comments.) Submission of a complete copy of the journal
article in which the study and its results are described is
preferred, but a complete reference (authors' names, name of
journal, volume, issue, pages, title, date) will be sufficient if
the complete article cannot be submitted. Include a brief narrative
explaining the reason for each addition, deletion, or substitution.
Raw data need not be submitted at this stage.
    Studies which are as yet unpublished but which are expected to
be accepted for publication before April 1, 2000 may be nominated.
An abstract of the study describing highlights of the study
(including species and strain, dosing regimen, duration of study,
number of animals per dose, endpoints evaluated and, if available,
results) must be submitted in order for the Selection Committee to
be able to evaluate the likelihood that the study will be a critical
study. As with published studies, a brief narrative explaining the
significance of as yet unpublished studies should be included.
    Studies which are completed but not published are not included
here. This list is being provided as an example of the kinds of
studies that may be appropriate for the Panel to consider. Final
selection of studies has not been made.
    Ashby J, Elliott BM. 1997. Reproducibility of endocrine
disruption data. Reg Toxicol Pharmacol 26:94-95.
    Ashby J, Tinwell H, Lefevre PA et al. 1997. Normal sexual
development of rats exposed to butyl benzyl phthalate from
conception to weaning. Reg Toxicol Pharmacol 26:102-118.
    Boettger-Tong H, Murthy L, Chiapetta C, et al. 1998. A case of a
laboratory animal feed with high estrogenic activity and its impact
on in vivo responses to exogenously administered estrogens. Environ
Health Perspect 106(7):369-373.
    Cagen SZ, Waechter JM Jr, Dimond SS, et al. 1999. Normal
reproductive organ development in CF-1 mice following prenatal
exposure to bisphenol A. Toxicol Sci 50:36-44.
    Colerangle JB, Roy D. 1997. Profound effects of the weak
environmental estrogen-like chemical bisphenol A on the growth of
the mammary gland of Noble rats. J Steroid Biochem Molec Biol 60(1-
2), 153-160.
    Makela SI, Pylkkanen LH, Santti RSS, Adlercreutz H. 1995.
Dietary soybean may be antiestrogenic in male mice. J Nutr 125:437-
445.
    Nagel SC, vom Saal FS, Thayer KA, et al. 1997. Relative binding
affinity-serum modified access (RBA-SMA) assay predicts the relative
in vivo bioactivity of the xenoestrogens bisphenol A and
octylphenol. Environ Health Perspect 105:70-76.
    Odum J. Pyrah ITG, Foster JR, et al. 1999. Comparative
activities of p-nonylphenol and diethylstilbestrol in Noble rat
mammary gland and uterotrophic assays. Reg Toxicol Pharmacol 29:184-
195.
    Portier C, Tritscher A, Kohl M. et al. 1993. Ligand/receptor
binding for 2,3,7,8-TCDD: implications for risk assessment.
Fundamental and Applied Toxicol 20:48-56.
    Sharpe RM, Fisher JS, Millar MM, et al. 1995. Gestational and
lactational exposure of rats to xenoestrogens results in reduced
testicular size and sperm production. Environ Health Perspect
103(12): 1136-1143.
    Sharp R, Turner KJ, Sumpter JP. 1998. Endocrine disruptors and
testis development [letter]. Environ Health Perspect 106(5): A220-
A221.
    Sheehan DM, Willingham E, Gaylor D, et al. 1999. No threshold
dose for estradiol-induced sex reversal of turtle embryos: how
little is too much? Environ Health Perspect 107:155-159.
    Spearow J, Doemeny P, Sera R, et al. 1999. Genetic variation is
susceptibility to endocrine disruption by estrogen in mice. Science
285:1259-1261.
    vom Saal FS, Quadagno DM, Even MD, et al. 1990. Biology of
Reproduction 43:751-761.
    vom Saal FS, Timms BG, Montano MM, et al. 1997. Prostate
enlargement in mice due to

[[Page 787]]

fetal exposure to low doses of estradiol or diethylstilbestrol and
opposite effects at high doses. Proc Natl Acad Sci USA 94:2056-2061.
    vom Saal FS, Cooke PS, Buchanan DL, et al. 1998. A
physiologically based approach to the study of bisphenol A and other
estrogenic chemicals on the size of reproductive organs, daily sperm
production, and behavior. Toxicol Indust Hlth 14(__):239-260.
    Welshons WV, Nagel SC, Thayer KA, et al. 1999. Low-dose
bioactivity of xenoestrogens in animals: fetal exposure to low doses
of methoxychlor and other xenoestrogens increases adult prostate
size in mice. Toxicol Indust Health 15:12-25.

[FR Doc. 00-228 Filed 1-5-00; 8:45 am]
BILLING CODE 4140-01-M

------------------------------







From ttweed@wildrockies.org Mon, 10 Jan 2000 22:12:16 -0700
Date: Mon, 10 Jan 2000 22:12:16 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] VF, VB  Nominations for Listing in 10th RoC

>From: NTP Mail <ntp@niehs.nih.gov>
>To: "'ntpmail@list.niehs.nih.gov'" <ntpmail@bobo.niehs.nih.gov>
>Subject: NTP UPDATE: Review of Nominations for Listing in the 10th RoC
>Date: Mon, 10 Jan 2000 15:46:44 -0500
>MIME-Version: 1.0
>Sender: owner-ntpmail@bobo.niehs.nih.gov
>Precedence: bulk
>Reply-To: ntp@niehs.nih.gov
>
>On January 20 & 21, 2000, the NTP Board of Scientific Counselors' Report on
>Carcinogens Subcommittee will meet to peer review the following nominations
>for listing in the 10th Report on Carcinogens (RoC).  The meeting is open to
>the public and includes an opportunity for public comment.
>
>Background documents on these nominations are available at the
>http://ntp-server.niehs.nih.gov/htdocs/liason/JanRoCMtg.html.  The meeting
>will be held at the Crystal City Marriott, 1999 Jefferson Davis Highway in
>Arlington, Virginia.
>
>Nominations being reviewed:
>
>Beryllium and Beryllium Compounds
>
>2,2-bis-(bromomethyl)-1,3-propanediol
>
>2,3-Dibromo-1-Propanol
>
>Dyes Metablized to Dimethoxybenzidine (Dimethoxybenzidine Dyes as a Class)
>
>Dyes Metabolized to Dimethylbenzidine (Dimethylbenzidine Dyes as a Class)
>
>IQ (2-Amino-3-methylimidazo [4,5-f]quinoline)
>
>Styrene-7,8-oxide
>
>Vinyl Bromide
>
>Vinyl Fluoride
>
>
>To SUBSCRIBE to the NTP Mailing List send mail to
>ntpmail-request@list.niehs.nih.gov with
>the word "subscribe" as the body of the message.
>
>To UNSUBSCRIBE, send mail to ntpmail-request@list.niehs.nih.gov with the
>command
>"unsubscribe" as the  body of the message.
>







From ttweed@wildrockies.org Mon, 10 Jan 2000 22:11:03 -0700
Date: Mon, 10 Jan 2000 22:11:03 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] PCBs-EPA seeks to update knowledge of their managemnt

(tho the comment sought here pertains to whether that ICR would be a burden).
--

    Abstract: [Snip]
    To meet its statutory obligations to regulate PCBs, EPA must obtain
sufficient information to conclude that specified activities do not
result in an unreasonable risk of injury to health or the environment.
EPA uses the information collected under the 40 CFR part 761
requirements to ensure that PCBs are managed in an environmentally safe
manner and that activities are being conducted in compliance with the
PCB regulations. The information collected by these requirements will
update the Agency's knowledge of ongoing PCB activities, ensure that
individuals using or disposing of PCBs are held accountable for their
activities, and demonstrate compliance with the PCB regulations.
Specific uses of the information collected include determining the
efficacy of a disposal technology; evaluating exemption requests and
exclusion notices; targeting compliance inspections; and ensuring
adequate storage capacity for PCB waste.
    This ICR consolidates six separate existing ICRs that address PCB
reporting and recordkeeping requirements, and includes additional or
revised requirements resulting from a final rule amending requirements
addressing the manufacture, processing, distribution in commerce, use,
cleanup, storage and disposal of PCBs, published June 29, 1998 (63 FR
35383) (FRL-5726-1). Detailed discussions of the existing ICRs and how
their associated reporting and/or recordkeeping burdens have changed as
a result of the final rule are found in the supporting statement for
the information collection that is the subject of this notice.
----




[Federal Register: January 10, 2000 (Volume 65, Number 6)]
[Notices]
[Page 1366-1369]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr10ja00-35]

=======================================================================
-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

[OPPTS-00284; FRL-6484-6]


PCBs Consolidated Reporting and Recordkeeping Requirements;
Request for Comment on Renewal of Information Collection Activities

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: In compliance with the Paperwork Reduction Act (PRA) (44
U.S.C. 3501 et seq.), EPA is seeking public comment and information on
the following Information Collection Request (ICR): PCBs: Consolidated
Reporting and Recordkeeping Requirements (EPA ICR No. 1446.07, OMB No.
2070-0112). This ICR involves a collection activity that is currently
approved and scheduled to expire on October 31, 2001, but also
consolidates six other existing ICRs. The information collected under
this ICR will help EPA prevent the improper handling and disposal of
polychlorinated biphenyls (PCBs) and to minimize the exposure of human
beings or the environment to PCBs. The ICR describes the nature of the
information collection activity and its expected burden and costs.
Before submitting this ICR to the Office of Management and Budget (OMB)
for review and approval under the PRA, EPA is soliciting comments on
specific aspects of the collection.

DATES: Written comments, identified by the docket control number OPPTS-
00284 and administrative record number AR-220, must be received on or
before March 10, 2000.
ADDRESSES: Comments may be submitted by mail, electronically, or in
person. Please follow the detailed instructions for each method as
provided in Unit III. of the ``SUPPLEMENTARY INFORMATION.'' To ensure
proper receipt by EPA, it is imperative that you identify docket
control number OPPTS-00284 and administrative record number AR-220 in
the subject line on the first page of your response.

FOR FURTHER INFORMATION CONTACT: For general information contact: Joe
Carra, Deputy Director, Office of Pollution Prevention and Toxics
(7401), Office of Pollution Prevention and Toxics, Environmental
Protection Agency, 401 M St., SW., Washington, DC 20460; telephone
number: (202) 554-1404; TDD: (202) 554-0551; e-mail address: TSCA-
Hotline@epa.gov.
    For technical information contact: Peggy Reynolds, National Program

[[Page 1367]]

Chemicals Division (7404), Office of Pollution Prevention and Toxics,
Environmental Protection Agency, 401 M St., SW., Washington, DC 20460;
telephone number: (202) 260-3965; fax number: (202) 260-1724; e-mail
address: reynolds.peggy@epa.gov.

SUPPLEMENTARY INFORMATION:

I. Does this Action Apply to Me?

    You may be potentially affected by this action if you currently
possess PCB items, PCB-contaminated equipment, or other PCB waste.
Potentially affected categories and entities may include, but are not
limited to:

------------------------------------------------------------------------
             Type of business                         SIC codes
------------------------------------------------------------------------
Manufacturing                               20-39
Oil and gas producers                       1311
Electric utility industry                   4911
Line-haul railroads                         4011
Telecommunications                          4810
Refuse systems                              4953
Trucking and warehousing                    4200
Sanitary services                           4950
Steam suppliers                             4960
Hospitals                                   8062
------------------------------------------------------------------------

    This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be affected by this
action. Other types of entities not listed in this table could also be
affected. The Standard Industrial Classification (SIC) codes are
provided to assist you and others in determining whether or not this
action might apply to certain entities. If you have any questions
regarding the applicability of this action to a particular entity,
consult the technical person listed under ``FOR FURTHER INFORMATION
CONTACT.''

II. How Can I Get Additional Information, Including Copies of this
Document and Other Related Documents?

A. Electronically

    You may obtain electronic copies of this document, and certain
other related documents that might be available electronically, from
the EPA Internet Home Page at http://www.epa.gov/. On the Home Page
select ``Laws and Regulations'' and then look up the entry for this
document under the ``Federal Register-Environmental Documents.'' You
can also go directly to the Federal Register listings at http://
www.epa.gov/fedrgstr/.

B. Fax-on-Demand

    Using a faxphone call (202) 401-0527 and select items 4073, 4074,
4075, 4076, and 4077 for a copy of the ICR.

C. In Person

    The Agency has established an official record for this action under
docket control number OPPTS-00284 and administrative record number AR-
220. The official record consists of the documents specifically
referenced in this action, any public comments received during an
applicable comment period, and other information related to this
action, including any information claimed as Confidential Business
Information (CBI). This official record includes the documents that are
physically located in the docket, as well as the documents that are
referenced in those documents. The public version of the official
record does not include any information claimed as CBI. The public
version of the official record, which includes printed, paper versions
of any electronic comments submitted during an applicable comment
period, is available for inspection in the TSCA Nonconfidential
Information Center, North East Mall Rm. B-607, Waterside Mall, 401 M
St., SW., Washington, DC. The Center is open from noon to 4 p.m.,
Monday through Friday, excluding legal holidays. The telephone number
for the Center is (202) 260-7099.

III. How Can I Respond to this Action?

A. How and to Whom Do I Submit the Comments?

    You may submit comments through the mail, in person, or
electronically. To ensure proper receipt by EPA, it is imperative that
you identify docket control number OPPTS-00284 and administrative
record number AR-220 on the subject line on the first page of your
response.
    1. By mail. Submit your comments to: Document Control Office
(7407), Office of Pollution Prevention and Toxics (OPPT), Environmental
Protection Agency, 401 M St., SW., Washington, DC 20460.
    2. In person or by courier. Deliver your comments to: OPPT Document
Control Office (DCO) in East Tower Rm. G-099, Waterside Mall, 401 M
St., SW., Washington, DC. The DCO is open from 8 a.m. to 4 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
DCO is (202) 260-7093.
    3. Electronically. Submit your comments and/or data electronically
by e-mail to: ``oppt.ncic@epa.gov,'' or mail your computer disk to the
address identified in Units III.A.1. and 2. Do not submit any
information electronically that you consider to be CBI. Electronic
comments must be submitted as an ASCII file avoiding the use of special
characters and any form of encryption. Comments and data will also be
accepted on standard disks in WordPerfect 6.1/8.0 or ASCII file format.
All comments in electronic form must be identified by docket control
number OPPTS-00284 and administrative record number AR-220. Electronic
comments may also be filed online at many Federal Depository Libraries.

B. How Should I Handle CBI that I Want to Submit to the Agency?

    Do not submit any information electronically that you consider to
be CBI. You may claim information that you submit to EPA in response to
this document as CBI by marking any part or all of that information as
CBI. Information so marked will not be disclosed except in accordance
with procedures set forth in 40 CFR part 2. In addition to one complete
version of the comment that includes any information claimed as CBI, a
copy of the comment that does not contain the information claimed as
CBI must be submitted for inclusion in the public version of the
official record. Information not marked confidential will be included
in the public version of the official record without prior notice. If
you have any questions about CBI or the procedures for claiming CBI,
please consult the technical person identified under ``FOR FURTHER
INFORMATION CONTACT.''

C. What Should I Consider when I Prepare My Comments for EPA?

    You may find the following suggestions helpful for preparing your
comments:
    1. Explain your views as clearly as possible.
    2. Describe any assumptions that you used.
    3. Provide copies of any technical information and/or data you used
that support your views.
    4. If you estimate potential burden or costs, explain how you
arrived at the estimate that you provide.
    5. Provide specific examples to illustrate your concerns.
    6. Offer alternative ways to improve the collection activity.
    7. Make sure to submit your comments by the deadline in this
notice.
    8. To ensure proper receipt by EPA, be sure to identify the docket
control number and administrative record number assigned to this action
in the

[[Page 1368]]

subject line on the first page of your response. You may also provide
the name, date, and Federal Register citation.

D. What Information is EPA Particularly Interested in?

    Pursuant to section 3506(c)(2)(A) of the Paperwork Reduction Act
(PRA), EPA specifically solicits comments and information to enable it
to:
    1. Evaluate whether the proposed collections of information are
necessary for the proper performance of the functions of the Agency,
including whether the information will have practical utility.
    2. Evaluate the accuracy of the Agency's estimates of the burdens
of the proposed collections of information.
    3. Enhance the quality, utility, and clarity of the information to
be collected.
    4. Minimize the burden of the collections of information on those
who are to respond, including through the use of appropriate automated
or electronic collection technologies or other forms of information
technology, e.g., permitting electronic submission of responses.

IV. What Information Collection Activity or ICR Does this Action
Apply to?

    EPA is seeking comments on the following ICR:
    Title: PCBs: Consolidated Reporting and Recordkeeping Requirements.
    ICR numbers: EPA ICR No. 1446.07, OMB No. 2070-0112.
    ICR status: This specific ICR is currently scheduled to expire on
October 31, 2001; note, however, that this ICR is a consolidation of
six separate existing ICRs that are scheduled to expire between
February 28, 2000 and October 31, 2001. These ICRs are identified and
discussed in the supporting statement for the subject information
collection. An Agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information, unless it displays
a currently valid OMB control number. The OMB control numbers for EPA's
information collections appear on the collection instruments or
instructions, in the Federal Register notices for related rulemakings
and ICR notices, and, if the collection is contained in a regulation,
in a table of OMB approval numbers in 40 CFR part 9.
    Abstract: Section 6(e)(1) of the Toxic Substances Control Act
(TSCA), 15 U.S.C. 2605(e), directs EPA to regulate the marking and
disposal of PCBs. Section 6(e)(2) bans the manufacturing, processing,
distribution in commerce, and use of PCBs in other than a totally
enclosed manner. Section 6(e)(3) establishes a process for obtaining
exemptions from the prohibitions on the manufacture, processing, and
distribution in commerce of PCBs. Since 1978, EPA has promulgated
numerous rules addressing all aspects of the life cycle of PCBs as
required by the statute. The regulations are intended to prevent the
improper handling and disposal of PCBs and to minimize the exposure of
human beings or the environment to PCBs. These regulations have been
codified in the various subparts of 40 CFR part 761. There are
approximately 100 specific reporting, third-party reporting, and
recordkeeping requirements covered by 40 CFR part 761.
    To meet its statutory obligations to regulate PCBs, EPA must obtain
sufficient information to conclude that specified activities do not
result in an unreasonable risk of injury to health or the environment.
EPA uses the information collected under the 40 CFR part 761
requirements to ensure that PCBs are managed in an environmentally safe
manner and that activities are being conducted in compliance with the
PCB regulations. The information collected by these requirements will
update the Agency's knowledge of ongoing PCB activities, ensure that
individuals using or disposing of PCBs are held accountable for their
activities, and demonstrate compliance with the PCB regulations.
Specific uses of the information collected include determining the
efficacy of a disposal technology; evaluating exemption requests and
exclusion notices; targeting compliance inspections; and ensuring
adequate storage capacity for PCB waste.
    This ICR consolidates six separate existing ICRs that address PCB
reporting and recordkeeping requirements, and includes additional or
revised requirements resulting from a final rule amending requirements
addressing the manufacture, processing, distribution in commerce, use,
cleanup, storage and disposal of PCBs, published June 29, 1998 (63 FR
35383) (FRL-5726-1). Detailed discussions of the existing ICRs and how
their associated reporting and/or recordkeeping burdens have changed as
a result of the final rule are found in the supporting statement for
the information collection that is the subject of this notice.
    Responses to the collection of information are mandatory (see 40
CFR part 761). Respondents may claim all or part of a notice
confidential. EPA will disclose information that is covered by a claim
of confidentiality only to the extent permitted by, and in accordance
with, the procedures in TSCA section 14 and 40 CFR part 2.

V. What are EPA's Burden and Cost Estimates for this ICR?

    Under the PRA, ``burden'' means the total time, effort, or
financial resources expended by persons to generate, maintain, retain,
or disclose or provide information to or for a Federal Agency. For this
collection it includes the time needed to review instructions; develop,
acquire, install, and utilize technology and systems for the purposes
of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable
instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review
the collection of information; and transmit or otherwise disclose the
information.
    The ICR provides a detailed explanation of this estimate, which is
only briefly summarized in this notice. The annual public burden for
this collection of information is estimated to average 0.57 hours per
response. The following is a summary of the estimates taken from the
ICR:
    Respondents/affected entities: Persons who currently possess PCB
items, PCB-contaminated equipment, or other PCB waste.
    Estimated total number of potential respondents: 1,300,240.
    Frequency of response: On occasion.
    Estimated total/average number of responses for each respondent: 1.
    Estimated total annual burden hours: 741,261.
    Estimated total annual burden costs:: $24,789,115.

VI. Are There Changes in the Estimates from the Last Approval?

    This ICR consolidates six separate existing ICRs that address PCB
reporting and recordkeeping requirements, and includes additional or
revised requirements resulting from a final rule amending requirements
addressing the manufacture, processing, distribution in commerce, use,
cleanup, storage and disposal of PCBs, published June 29, 1998 (63 FR
35383). Therefore any change in estimated burden is more meaningfully
expressed as the difference between the current combined burden of the
six existing ICRs compared with the estimated burden identified in the
information collection that is the subject of this notice, rather than
the difference

[[Page 1369]]

between the current and estimated burden of the subject information
collection only.
    The combined burden of the six existing ICRs totals 2,007,618
hours, while the burden for this consolidated ICR, as noted above, is
estimated to be 741,261 hours, a net burden reduction of 1,266,357
hours. This reduction reflects numerous factors, including program
changes and adjustments to the burdens of specific existing reporting
or recordkeeping requirements, revised estimates regarding the total
number of respondents resulting from new data gathered in preparing the
consolidated ICR effort, updated Agency analyses, and estimate
adjustments that were made for consistency with more recent Agency
reports, plus the addition of burden estimates associated with
requirements that were overlooked in the various existing ICRs and
burden associated with new reporting and recordkeeping requirements
contained within the final rule. Identification and detailed
discussions of the existing ICRs and how their associated reporting
and/or recordkeeping burdens have changed as a result of the final rule
are found in section 6(e), Reasons for Change in Burden, of the
supporting statement for the subject information collection.

VII. What is the Next Step in the Process for this ICR?

    EPA will consider the comments received and amend the ICR as
appropriate. The final ICR package will then be submitted to OMB for
review and approval pursuant to 5 CFR 1320.12. EPA will issue another
Federal Register notice pursuant to 5 CFR 1320.5(a)(1)(iv) to announce
the submission of the ICR to OMB and the opportunity to submit
additional comments to OMB. If you have any questions about this ICR or
the approval process, please contact the technical person listed under
``FOR FURTHER INFORMATION CONTACT.''

List of Subjects

    Environmental protection, Reporting and recordkeeping requirements.

    Dated: December 29, 1999.

Susan H. Wayland,

Deputy Assistant Administrator for Prevention, Pesticides and Toxic
Substances.

[FR Doc. 00-493 Filed 1-7-00; 8:45 am]
BILLING CODE 6560-50-F

------------------------------







From ttweed@wildrockies.org Mon, 10 Jan 2000 23:42:32 -0700
Date: Mon, 10 Jan 2000 23:42:32 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] Re:Reply

Some posts from these people have been logical, others not.  A couple days
ago one asked us to assume PVC (~50% of Cl use, and climbing) is a social
need; a 'must have'.  This assumption was quietely made, and followed by
the presumed main argument about controlling incinerator emissions.  People
have got to recognize bad logic!  Other posts from these people have
similarly been couched in reasonable sounding arguments but were actually
quite radical arguments--eg that dioxin in the env is safe if at a certain
level, or that drinking water disinfectn w/ Cl is another irreducible need
for Cl.  Other radical points have also been made that don't come to mind.
This is disingenious.  Always question assumptions.

BTW, on the disinfection q., I posted a short p'graph in a post on another
subject, so not all may have seen it.  Cities as Cincinatti and many others
use filtration and perhaps ozone.  O3 is a much more powerful oxidant than
Cl, and giardia cysts do not resist it the way they do Cl.  Residual
disinfection through to the point of use could be accomplished w/ far far
less Cl, if any, depending on the desire to manage risk and think.

Does anyone know hy so many dugs are compounded w/ HCl, and why this is
such a critical use of Cl (tho an infinitesmal one)?

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth







From Jon.Campbell@MetraTech.com Tue, 11 Jan 2000 09:58:08 -0500
Date: Tue, 11 Jan 2000 09:58:08 -0500
From: Jon Campbell Jon.Campbell@MetraTech.com
Subject: [Dioxin-l] Re:Reply

Tony,

    Re: HCL in drugs: I assume much drug synthesis is done via
hydrolyzation, that is, the action of HCL on some other substance. I believe
this step makes the substance easily assimilated, such as "hydrolyzed
vegetable protein (HVP)", the action of hydrochloric acid on protein. But,
I'm not a chemist or biologist, so I'm probably shooting in the dark. (As a
side note, I am told that HVP is another term commonly used for MSG, which,
according to the book "The Taste That Kills" is not good for us...).
 
Jon

-----Original Message-----
From: Tony Tweedale [mailto:ttweed@wildrockies.org]
Sent: Tuesday, January 11, 2000 1:43 AM
To: dioxin-l@venice.essential.org
Subject: [Dioxin-l] Re:Reply


Some posts from these people have been logical, others not.  A couple days
ago one asked us to assume PVC (~50% of Cl use, and climbing) is a social
need; a 'must have'.  This assumption was quietely made, and followed by
the presumed main argument about controlling incinerator emissions.  People
have got to recognize bad logic!  Other posts from these people have
similarly been couched in reasonable sounding arguments but were actually
quite radical arguments--eg that dioxin in the env is safe if at a certain
level, or that drinking water disinfectn w/ Cl is another irreducible need
for Cl.  Other radical points have also been made that don't come to mind.
This is disingenious.  Always question assumptions.

BTW, on the disinfection q., I posted a short p'graph in a post on another
subject, so not all may have seen it.  Cities as Cincinatti and many others
use filtration and perhaps ozone.  O3 is a much more powerful oxidant than
Cl, and giardia cysts do not resist it the way they do Cl.  Residual
disinfection through to the point of use could be accomplished w/ far far
less Cl, if any, depending on the desire to manage risk and think.

Does anyone know hy so many dugs are compounded w/ HCl, and why this is
such a critical use of Cl (tho an infinitesmal one)?

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth




_______________________________________________
Dioxin-l mailing list
Dioxin-l@lists.essential.org
http://lists.essential.org/mailman/listinfo/dioxin-l





From pat.costner@dialb.greenpeace.org Tue, 11 Jan 2000 08:50:47 -0600
Date: Tue, 11 Jan 2000 08:50:47 -0600
From: pat.costner@dialb.greenpeace.org pat.costner@dialb.greenpeace.org
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distribution

Dear Mr. Bell,

I urge you to give the abstract of the study by Payment (1999)  a 
more careful reading.  You have interpreted it to say that "E coli is 
inactivated by residual chlorine throughout the distribution 
system."  This differs considerably from the actual wording of the 
abstract, as follows: 

    "Except for Escherichia coli, microorganisms remained relatively
    unaffected in water from the distribution systems tested. When
    sewage was added to the water samples, indigenous thermotolerant
    coliforms were inactivated only when water was obtained from
    sites very close to the treatment plant and containing a high
    residual chlorine concentration." 

You then note, " Given that E coli is a principal contaminant of
sewage (and in turn the water supply system), and can be highly
pathogenic (eg E coli 0157), this abstract can easily be used to
 make a case for chlorination of water supplies."   With this, I
 would suggest that you have missed a major finding of the study:

    "Clostridium perfringens was barely inactivated, suggesting that
    the most resistant pathogens such as Giardia lamblia,
    Cryptosporidium parvum, and human enteric viruses would not  
   be inactivated. "

 Please note that the Clostridium perfringens used by Payment
 (1999) as an indicator for Giardia lambia, Cryptosporidium
 parvum, and human enteric viruses, was "barely inactivated".  
Giardia lambia and Cryptosporidium parvum also commonly occur in
sewage and have been identified as the causative agents in
numerous disease outbreaks.  For example, in his
recent review  -- "Microbiological Safety of  Drinking Water: United 
States and Global Perspectives",  Environ Health Perspect 107
( Suppl 1):191-206 (1999) -- Ford notes as follows: 

    "G. lamblia and C. parvum 
    Smith and Lloyd (111) have  recently reported that these two protozoa 
    are responsible for     more than 600 million infections worldwide, of which a
    significant proportion are waterborne. For example, 60% of Giardia cases 
    are estimated to be waterborne in the United States (84), with a point 
    estimate of the annual incidence of giardiasis of 260,000 cases (2).
    Until recently, giardiasis was the most frequently reported waterborne
    disease ( 112,113). Cryptosporidiosis has now overtaken giardiasis,
    with a point  estimate of 420,000 annual waterborne cases in the United 
    States (2)." 

In summary,  your suggestion that the findings by Payment (1999)  
"can easily be used to make a case for chlorination of water 
supplies"  stands in direct opposition to Payment's conclusion:

    "... the maintenance of a free residual concentration in a 
    distribution system does not provide a significant inactivation 
    of pathogens, could even mask events of contamination of the 
    distribution, and thus would provide only a false sense of 
    safety with little active protection of public health." 

On 10 Jan 00, at 0:20, david bell wrote:
[Dioxin-l] Re: Poor efficacy of residual chlorine

From:           	"david bell" <burnt_paper@hotmail.com>
To:             	dioxin-l@venice.essential.org
Subject:        	[Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distribution
Date sent:      	Mon, 10 Jan 2000 00:20:26 GMT

> If I read the abstract below correctly, E coli is inactivated by residual
> chlorine throughout the distribution system. Given that E coli is a
> principal contaminant of sewage (and in turn the water supply system), and
> can be highly pathogenic (eg E coli 0157), this abstract can easily be
> used to make a case for chlorination of water supplies.
> 
> I am not sure what to make of the abstract; viruses can be very difficult
> to kill, and (I believe) some clostridia have a spore, again making them
> very difficult to disinfect. I don't know that E coli isn't a much more
> representative bacterial pathogen than the others this abstract measures.
> 
> david bell

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
Greenpeace
P.O. Box 548
 or 512 County Road 2663
Eureka Springs, Arkansas 72632
ph: 1 501 253 8440
fx: 1 501 253 5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~





From Kaltofen@aol.com Tue, 11 Jan 2000 10:33:58 EST
Date: Tue, 11 Jan 2000 10:33:58 EST
From: Kaltofen@aol.com Kaltofen@aol.com
Subject: [Dioxin-l] Re:Reply

I would reckon that HCL is much less likely to destroy the active part of a 
drug molecule while still giving the molecule what the drug designer is 
looking for from an acid salt, namely water solubility.

Nitric and sulfuric acids are more likely to attack the backbone of the 
molecule. (Instead of just a lose proton or two as is the case with HCL.)

Marco Kaltofen





From Jon.Campbell@MetraTech.com Tue, 11 Jan 2000 10:45:06 -0500
Date: Tue, 11 Jan 2000 10:45:06 -0500
From: Jon Campbell Jon.Campbell@MetraTech.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking
 water distr...

David,

    You were not around last year when it was reported (I believe by Charlie
Cray) that a number of midwestern U.S. communities had lost their entire
water supplies when it was discovered that vinyl chloride monomer was
leaching from their water supply pipes. It is also fairly well accepted
today that the vinyl chloride monomer found in most municipal dump effuent
and contaminated groundwater is due to leaching of VCM from PVC and/or
breakdown of PVC into VCM. Your knowledge of the theory of plastics does not
seem to bear itself out in practice.

Regards
Jon Campbell
-----Original Message-----
From: david bell [mailto:burnt_paper@hotmail.com]
Sent: Sunday, January 09, 2000 6:33 PM
To: Evertcc@aol.com
Cc: dioxin-l@lists.essential.org
Subject: Re: [Dioxin-l] Re: Poor efficacy of residual chlorine in
drinking water distr...


Hi Carl
>Connie,
>
>I would be more interested in knowing about any contamination from the PVC
>pipe now used in many water systems than of the chlorination of the water
>itself.

PVC is long-chain, and essentially insoluble in water. Hence it has no 
toxicity. Vinyl chloride monomer is a good human carcinogen, but there is 
very little of it in PVC, it gets diluted out a lot, and you can detect the 
resulting cancer very easily. VCM gives cholangiocarcinoma in humans, and I 
am not aware in any variation in the rate of this rare human cancer.

>My other concern is the combination of chlorine and organic compounds to 
>form
>triholomethane for example. I don't think that we can just look at free
>chlorine by itself.

I guess you are probably aware that there is a massive ongoing debate around

this issue. Some people argue that the (potential) cancer risk from tiny 
quantities of chloromethanes are significant. Others, that the public health

benefits of chlorination vastly outweigh any cancer risk. There is a 
well-founded argument that the carcinogenicity of trichloromethane has a no 
effect level- and that the low levels in water are without significance.

cheers
david

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From vbushnell@essential.org Tue, 11 Jan 2000 11:40:44 -0500 (EST)
Date: Tue, 11 Jan 2000 11:40:44 -0500 (EST)
From: Vergil Bushnell vbushnell@essential.org
Subject: [Dioxin-l] Open burning ban in Japan

Asahi News Service 

                                            January 11, 2000, Tuesday 

LENGTH: 327 words 

HEADLINE: OPEN-AIR WASTE BURNING TARGETED 

DATELINE: TOKYO 

BODY: 
   The Health and Welfare Ministry plans to ban open-air waste burning and
seek hefty fines or imprisonment for violators, ministry officials said
on Jan. 7. 

The ministry made the decision to deal with the growing number of
complaints about neighborhood smoke, stenches and possible cancer-causing
dioxins caused by the burning waste, the officials said. 

Current laws on waste disposal do not clearly prohibit the burning of
garbage outdoors. To ban the practice, the ministry plans to submit
revisions
to the laws at the next ordinary Diet session that starts this month. 

The revisions will stipulate that violators face prison terms of up to one
year or maximum fines of 3 million yen ($28570). 

However, the revisions will not ban bonfires using scrap wood, the burning
of straw in rice fields, or fires to prevent agricultural products from
freezing, the officials said. 

Current laws on waste disposal only state that the burning of waste must
be conducted in incinerators. People who burn waste outdoors in
violation of the laws are only ordered by the government to stop such
action. 

Such government orders have had little effect because they are simply
administrative measures that carry no penalties, such as prison terms or
fines. 

Waste-disposal firms warned by the government have often burned garbage
again at other locations. 

In addition, the government cannot issue the order to unauthorized waste
disposal firms that burn waste outdoors. 

According to Health and Welfare Ministry statistics, the number of
waste-burning incidents in open air, confirmed by prefectural governments
throughout the country, stood at 5,385 in fiscal 1998, an increase of 40
percent from fiscal 1997, and more than double that of fiscal 1996. 

Of those cases, 80 percent were conducted by companies not including waste
disposal firms. 

In the 5,385 burnings of fiscal 1998, at least 40,000 tons of waste was
burned, according to the statistics. 

Vergil Bushnell
Multinationals Resource Center

email: vbushnell@essential.org
phone: 202.387.8030
address: PO Box 19405, Washington DC 20036






From vbushnell@essential.org Tue, 11 Jan 2000 11:42:51 -0500 (EST)
Date: Tue, 11 Jan 2000 11:42:51 -0500 (EST)
From: Vergil Bushnell vbushnell@essential.org
Subject: [Dioxin-l] Open Burning Restrictions in Malaysia

New Straits Times (Malaysia) 

                                                January 11, 2000 

SECTION: Pg. 1 

LENGTH: 669 words 

HEADLINE: New law on open burning (HL) 

BYLINE: By Esther Tan 

DATELINE: Kuala Lumpur 

BODY: 
   KUALA LUMPUR, Mon. - Those planning to conduct open burning to dispose
of 
infected crops or carcasses of diseased animals must inform the Department 
of Environment and get approval from relevant agencies under new 
legislation which will be enforced next month. 

They must adhere to a set of conditions or face a fine of up to RM2,000 
under the new Environmental Quality (Prescribed Activities)(Open Burning) 
Order which will be gazetted by the end of next month. 

They are also liable to a maximum fine of RM500,000 or up to five years' 
jail or both under the Environmental Quality Act if their case is taken to 
court. 

DOE director-general Rosnani Ibarahim told the New Straits Times that 
the draft of the Order, drawn up following the severe haze in 1998, has 
been finalised and would be submitted to the Cabinet after the Hari Raya 
holidays. 

"We plan to gazette and enforce the Order by the end of next month," she 
said. 

The Order is made possible with the 1998 amendments to the Environmental 
Quality Act (EQA) which also saw the introduction of stiffer penalties for 
open burning. 

At present, some of the conditions under the Order are being implemented 
as mere guidelines. Once gazetted, the conditions will have legal force. 

Under the Order, open burning will only be allowed for prescribed 
activities such as religious practices, training and research activities, 
disease control, and agricultural practices which involve the burning of 
sugar cane leaves and padi stalks, and shifting cultivation. 

The existing Environmental Quality (Clean Air) Regulations 1978, allow 
open burning for these activities. The difference is that the DOE does not 
need to be informed beforehand and there are no stringent conditions to 
adhere to. 

Rosnani said the Order will make it a requirement for those wishing to 
carry out open burning for these exempted activities to provide prior 
notification to the DOE. 

Those wanting to dispose of infected crops and carcasses of diseased 
animals or poultry for disease and pest control must get approval from the 
departments of Agriculture and Veterinary Services. 

One of the conditions is that burning of carcasses can only be carried 
out in areas where other alternatives such as incinerators are not 
available. The burning must be conducted in designated areas determined by 
the DOE. 

Open burning activities must cease if the Air Pollutant Index breaches 
100. All open burning must also be supervised. 

Burning of garden refuse on the premises of private residences will 
continue to be allowed under the Order provided it is done between 8am and 
6pm. Private residents are not required to inform the DOE. 

"Under the Order, we will no longer issue written permission for open 
burning such as for land-clearing by plantations. This means open burning 
for any other activities other than the prescribed activities will no 
longer be allowed," said Rosnani. 

The Order will remove ambiguities which obstruct effective enforcement 
as the prescribed list is very specific on types of activities. 

For instance, Rosnani said the Order clearly defined the types of 
agricultural practices where open burning is allowed. 

Essentially, the exemption is given to smallholders and those carrying 
out traditional agricultural practices as they cannot afford zero-burning 
technology. 

Big plantation companies have no excuse. The plantation sector is lumped 
under agricultural practices under the current regulations. 

"Under normal circumstances, they will no longer be allowed to carry out 
open burning because they are capable of zero-burning techniques," said 
Rosnani. 

The Order is the second stage of the DOE's efforts to ensure stringent 
enforcement to curb local sources of haze. It had amended the EQA to raise 
the maximum fine from RM100,000 to RM500,000 for open burning. It also 
made land owners responsible for fires on their land unless they could 
prove that the open burning occurred outside of their control. 

Vergil Bushnell
Multinationals Resource Center

email: vbushnell@essential.org
phone: 202.387.8030
address: PO Box 19405, Washington DC 20036






From burnt_paper@hotmail.com Tue, 11 Jan 2000 19:00:11 GMT
Date: Tue, 11 Jan 2000 19:00:11 GMT
From: david bell burnt_paper@hotmail.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water
 distribution

Hi Pat
perhaps you can explain the wording of the abstract to me: I have not seen 
the paper, and do not know what information it contains.

>microorganisms remained relatively
>     unaffected in water from the distribution systems tested

I understand this-

>except for Escherichia coli

Can you please explain to me what this means ? Does this not mean that E 
coli is affected by water from the distribution systems tested ? Is this not 
the wording of the abstract ?

If E coli is disinfected, is this not a good thing ?

If other bacteria and viruses are not inactivated, that is clearly a 'bad 
thing'; but you don't make the 'bad thing' better by adding another 
pathogen, E coli, to the mix.

david

>Dear Mr. Bell,
>
>I urge you to give the abstract of the study by Payment (1999)  a
>more careful reading.  You have interpreted it to say that "E coli is
>inactivated by residual chlorine throughout the distribution
>system."  This differs considerably from the actual wording of the
>abstract, as follows:
>
>     "Except for Escherichia coli, microorganisms remained relatively
>     unaffected in water from the distribution systems tested. When
>     sewage was added to the water samples, indigenous thermotolerant
>     coliforms were inactivated only when water was obtained from
>     sites very close to the treatment plant and containing a high
>     residual chlorine concentration."
>
>You then note, " Given that E coli is a principal contaminant of
>sewage (and in turn the water supply system), and can be highly
>pathogenic (eg E coli 0157), this abstract can easily be used to
>  make a case for chlorination of water supplies."   With this, I
>  would suggest that you have missed a major finding of the study:
>
>     "Clostridium perfringens was barely inactivated, suggesting that
>     the most resistant pathogens such as Giardia lamblia,
>     Cryptosporidium parvum, and human enteric viruses would not
>    be inactivated. "
<snip>
______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com






From Jon.Campbell@MetraTech.com Tue, 11 Jan 2000 14:21:55 -0500
Date: Tue, 11 Jan 2000 14:21:55 -0500
From: Jon Campbell Jon.Campbell@MetraTech.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking
 water distribution

David,

     I can't figure out whether you are being disingenuous or just not
understanding what you just wrote. Look at it again:

>	Except for Escherichia coli, microorganisms remained relatively
>     unaffected in water from the distribution systems tested. When
>     sewage was added to the water samples, indigenous thermotolerant
>     coliforms were inactivated only when water was obtained from
>     sites very close to the treatment plant and containing a high
>     residual chlorine concentration."

1. The abstract says first that other microorganisms are relatively
unaffected. This makes chlorine, at best, a poor choice because it provides
a false sense of security against the major vectors which cause disease from
water systems, that is, those other than e. coli. This is what Pat Costner
said in her last message.

2. The abstract says that coliforms (e. coli) are only inactivated ONLY when
water was obtained from sites VERY CLOSE to the treatment plant and
containing a HIGH residual chlorine concentration. This again makes chlorine
a poor choice because people think the residual chlorine is killing e. coli
throughout the system when it isn't. This is what Pat Costner said in her
last message.

Please, this debate is getting very silly. You keep on throwing up the
standard organochlorine industry straw men, and we keep on having to tear
them down. Are you reading from the a Chlorine Chemical Council flyer, or
what? This is getting very tiresome.

Why are you doing this, or should I ask, who do you work for?

This dioxin list has been around for several years. If you want to see all
the arguments about this, you can read them in the archives. The intent of
this list is for dioxin researchers and activists to share information about
dioxin exposure and its reduction, not to waste our time tearing down
industry straw men.

Thanks
Jon Campbell

-----Original Message-----
From: david bell [mailto:burnt_paper@hotmail.com]
Sent: Tuesday, January 11, 2000 2:00 PM
To: pat.costner@dialb.greenpeace.org
Cc: dioxin-l@venice.essential.org
Subject: Re: [Dioxin-l] Re: Poor efficacy of residual chlorine in
drinking water distribution


Hi Pat
perhaps you can explain the wording of the abstract to me: I have not seen 
the paper, and do not know what information it contains.

>microorganisms remained relatively
>     unaffected in water from the distribution systems tested

I understand this-

>except for Escherichia coli

Can you please explain to me what this means ? Does this not mean that E 
coli is affected by water from the distribution systems tested ? Is this not

the wording of the abstract ?

If E coli is disinfected, is this not a good thing ?

If other bacteria and viruses are not inactivated, that is clearly a 'bad 
thing'; but you don't make the 'bad thing' better by adding another 
pathogen, E coli, to the mix.

david

>Dear Mr. Bell,
>
>I urge you to give the abstract of the study by Payment (1999)  a
>more careful reading.  You have interpreted it to say that "E coli is
>inactivated by residual chlorine throughout the distribution
>system."  This differs considerably from the actual wording of the
>abstract, as follows:
>
>     "Except for Escherichia coli, microorganisms remained relatively
>     unaffected in water from the distribution systems tested. When
>     sewage was added to the water samples, indigenous thermotolerant
>     coliforms were inactivated only when water was obtained from
>     sites very close to the treatment plant and containing a high
>     residual chlorine concentration."
>
>You then note, " Given that E coli is a principal contaminant of
>sewage (and in turn the water supply system), and can be highly
>pathogenic (eg E coli 0157), this abstract can easily be used to
>  make a case for chlorination of water supplies."   With this, I
>  would suggest that you have missed a major finding of the study:
>
>     "Clostridium perfringens was barely inactivated, suggesting that
>     the most resistant pathogens such as Giardia lamblia,
>     Cryptosporidium parvum, and human enteric viruses would not
>    be inactivated. "
<snip>
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From vbushnell@essential.org Tue, 11 Jan 2000 15:06:44 -0500 (EST)
Date: Tue, 11 Jan 2000 15:06:44 -0500 (EST)
From: Vergil Bushnell vbushnell@essential.org
Subject: [Dioxin-l] PVC Plant In China

Here is a PVC plant project,
courtesy the World Bank's webpage.

An incinerator will be included to treat "non condensible gas".

Sincerely,

Vergil
_____________

Project Name         China-Suzhou PVC

Region               East Asia and Pacific

Sector               Fertilizer and Other Chemicals

Project No.          008213

1.                   Suzhou PVC is a joint venture between the Westlake 
Group of the U.S.A. and Norsk Hydro a.s. of Norway, as foreign 
investors, and China Jiangsu Chemical Pesticide Group Co. and China 
Taicang Petrochemical Co., as local shareholders.  Both Westlake and 
Norsk Hydro are major producers of PVC with a combined capacity of over 
600,000 tpy, providing the project with the necessary technical and 
marketing expertise.  The proposed project involves the construction and 
operation of a 100,000 mtpa polyvinyl chloride (PVC) resin plant and a 
PVC film calendaring facility with a capacity of up to 24,000 mtpa 
within an existing industrial estate in Suzhou, Jiangsu Province, China.

2.                   This is a category B project according to IFC's 
environmental review procedure because specific impacts may result which 
can be avoided or mitigated by adhering to generally recognized 
performance standards, guidelines or design criteria.  The review of 
this project consisted of information submitted by the project sponsor 
and the technical appraisal and site review completed by IFC's 
Chemicals, Petrochemicals and Fertilizers Department staff.  The 
following potential environmental, health and safety impacts of this 
project were analyzed:

                     . site location and infrastructure;
                     . processes and techniques used;
                     . air emissions;
                     . liquid effluent management;
                     . solid waste management;
                     . environmental and safety standards applied; and
                     . emergency prevention and response.

The information provided about how these potential impacts would be 
addressed in the Suzhou PVC project is summarized in the paragraphs that 
follow.

3.                   The manufacturing facility will be located within 
an existing industrial estate at the Yantze River bank north of 
Shanghai.  The raw material, Vinyl Chloride Monomer (VCM), will be 
received as bulk deliveries by ship, utilizing an existing pier at the 
neighboring company in the industrial estate.  No residents are living 
within the industrial estate.

4.                   The PVC manufacturing plant will be operated based 
on polymerization of imported VCM and will use the suspension method.  
The polymerization section consists of two reactors and a blowdown tank.  
VCM, a suspending agent, buffer, catalyst, and water are charged to the 
reactors.  The reaction mass is heated using steam.  During 
polymerization reaction heat is removed through condenser and the 
reactor jacket.  After the reaction is completed, the batch is 
transferred to the blowdown tank where un-reacted VCM is removed.  The 
PVC slurry is then stripped, dried, stored and packed in bags for 
shipment.

5.                   All VCM removed in the process is collected and fed 
to the recovery section, where VCM is recovered and recycled.  The plant 
will also include an incinerator facility.  Non-condensable gas is sent 
to the incinerator for disposal.  The off-gas from the incinerator is 
treated with a diluted caustic soda solution to neutralize HCl.  This 
off-gas will be the only emission from the plant and will comply with 
local requirements and World Bank guidelines.

6.                   The plant will include wastewater treatment and 
recycling of process waste water.  All process wastewater is collected 
and treated by stripping and precipitation of PVC powder.  The 
wastewater is then sent to the wastewater treatment system for partial 
reuse in the plant.

7.                   The process will not generate solid waste, and the 
municipal garbage disposal system will be used for domestic solid waste.

8.                   The plant operation system provides interlocking 
capabilities and controls to ensure the plant performs in an 
environmentally safe and efficient manner.  The plant design is based on 
U.S. engineering specifications for environment and safety.

9.                   As VCM is a hazardous and flammable chemical, 
significant emergency prevention and response measures will be 
implemented as follows:

        incoming ships and barges will have the individual cargo hold 
unloaded in sequence to avoid and limit spills.  To prevent further 
migration of any spill on the water, floating booms will be available as 
an emergency response measure;
        area monitors will be located throughout the plant to detect the 
presence of VCM vapors at low concentration levels.  These monitors will 
alert personnel to find and repair all leaks immediately;
        storage tanks for flammable materials are with dikes and isolated 
from manufacturing areas and from the plant perimeter.  Proper designed 
relief systems and avoidance of ignition sources within the plant will 
further minimize the risk of fires.  Emergency response to fires will 
automatically be activated by heat-sensitive, manually actuated and 
light-sensitive devices;
        emergency response to fires includes combinations of water deluge 
from fixed spray, monitors, local hose reels and extinguisher; and
        a HAZOP analysis will be prepared prior to mechanical completion.

10.                  IFC will ensure ongoing compliance with World Bank 
environmental, health and safety policies and guidelines during the life 
of the project by evaluating monitoring reports submitted annually to 
IFC by Suzhou PVC and by conducting periodic supervision.

11.                  Based on its review of available information 
regarding potential environmental impacts and proposed mitigation 
measures, IFC concludes that Suzhou PVC's proposed project is designed 
to meet World Bank environmental, health and safety policies and 
guidelines, and host country requirements.

_____

Vergil Bushnell
Multinationals Resource Center

email: vbushnell@essential.org
phone: 202.387.8030
address: PO Box 19405, Washington DC 20036






From agrace@nrdc.org Tue, 11 Jan 2000 13:15:36 -0700
Date: Tue, 11 Jan 2000 13:15:36 -0700
From: Ami Grace agrace@nrdc.org
Subject: [Dioxin-l] Coordinate comments on Biosolids pcdd/f/pcb rule

as Caroline Snyder & Ihave been posting lately, all indications are that
EPA is off by c. 2 orders of maginitude in this rule (300 ppt vs, say,
0.5-3.0 ppt; the latter using valid exposure modelling such as WI DPH or
ATSDR's soil screening levels, and the draft Dioxin Reasessment TDI "safe"
dose of 0.01 pg/kg/d).  No doubt to sneak in yet another lax dioxin rule
before finalizing the Reassessment.  These bureaucrats sure can be callous
of that basic right, health.	-tony t.
---


On December 15, 1999, EPA offered a proposed rule for the regulation of furans,
dioxins and coplanar PCBs in biosolids for land application.  A fact sheet and
the rule can be found at http://www.epa.gov/ost/biosolids/
Comments are due on Feb. 22, 2000.

Is anyone planning on commenting on this regulation? If so, please contact
Nancy
Stoner with NRDC-- DC who is interested in coordinating comments (Nancy can be
reached at nstoner@nrdc.org or 202-289-2394).

Thank you,
Ami Grace, CWN
_____________________________________________________________
Keep up with breaking news! Join our Hot Topics list.
http://www.topica.com/lists/breakingnews/t/12







From pat.costner@dialb.greenpeace.org Tue, 11 Jan 2000 15:08:25 -0600
Date: Tue, 11 Jan 2000 15:08:25 -0600
From: pat.costner@dialb.greenpeace.org pat.costner@dialb.greenpeace.org
Subject: [Dioxin-l] RE: Dioxins:  Natural or Manmade?


Greenpeace:  Pat Costner, May 1999

                   Dioxins:  Natural or Manmade?

In 1995, U.S. Environmental Protection Agency Science Advisory Board 
considered the question in its review of Anthropogenic (manmade) vs. 
Natural Sources of Dioxin and concluded:

    =93[T]he observation in the late 1970s that dioxins are produced 
    by the combustion of many common materials, including 
    municipal solid waste =85 led some scientists to suggest that 
    dioxins had been with us since =91the advent of fire=92 and that 
    dioxins could be produced by natural combustion (for example, 
    by forest fires). At that time, there were some suggestions that 
    observed levels of dioxins were primarily the result of coal 
    combustion or perhaps of wood burned in small stoves.=94 

    =93This speculation was largely refuted by sediment core studies, 
    both in the United States (primarily in the Great Lakes) and in 
    Europe, which indicated that environmental dioxin levels 
    increased significantly beginning about 1935-40 (see Volume II, 
    pages 3-92 to 3-94).  
    
    =93Since the advent of fire clearly predated this time, it can be 
    concluded that dioxins were largely anthropogenic and associated 
    with events taking place around 1935-40. What were these 
    events? Coal combustion could be ruled out because the 
    consumption of coal in the United States was essentially constant 
    from the turn of the century until about 1970; this record did not 
    agree with the sediment core data.  
    
This statement by the USEPA SAB then suggests what has changed. 
The major source of dioxin in the environment is not combustion by 
itself. The source, rather, is the production and combustion of certain 
man-made (anthropogenic) chlorine containing materials that first 
began circulating in large quantities in the period following 1930. 
    
    =93The explanation is likely to be the introduction of chlorinated 
    organic compounds (polyvinyl chloride and chlorinated pesticides 
    are but two examples) in the 1935-40 time-frame. Other sources 
    such as leaded gasoline (which commonly contained ethylene 
    dichloride and ethylene dibromide), diesel emissions, and PCBs 
    are also possibly significant contributors. 
    
    =93Although the details of dioxin formation are not yet quantitatively=
 
    understood, the introduction of these chlorinated products into 
    wastes that were combusted appears to be the most likely cause 
    of the increased dioxin deposition measured in sediments.=94

Source: U.S. Environmental Protection Agency Science Advisory 
Board, 1995. A Second Look at Dioxin: Science Advisory Board's 
review of the Draft Dioxin Exposure and Health Effects Reassessment 
Documents. EPA-SAB-EC-95-021, Washington, D.C., September 29, 
1995


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
Greenpeace
P.O. Box 548
 or 512 County Road 2663
Eureka Springs, Arkansas 72632
ph: 1 501 253 8440
fx: 1 501 253 5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~





From kefcrowe@acs.eku.edu Tue, 11 Jan 2000 17:40:39 -0800
Date: Tue, 11 Jan 2000 17:40:39 -0800
From: Elizabeth Crowe kefcrowe@acs.eku.edu
Subject: [Dioxin-l] New environmental violations alleged at Utah chemical weapons
 incinerator

--============_-1264480848==_ma============
Content-Type: text/plain; charset="us-ascii"

CHEMICAL WEAPONS WORKING GROUP
PO Box 467  Berea, KY 40403
606-986-7565  606-986-2695
kefwilli@acs.eku.edu   www.cwwg.org

                                      for further information:
                                     Craig Williams  (606) 986-7565
                                     Bob Schaeffer   (941) 395-6773
                                     Mick Harrison   (606) 321-1586

for use after 1pm EST, Tues. Jan. 11, 2000 news conference
NEW WHISTLEBLOWER SAYS U.S. ARMY ENGAGED IN FRAUD, CORRUPTION; HID
ENVIRONMENTAL VIOLATIONS
TO WIN UTAH CHEM. WEAPONS INCINERATOR PERMIT;
EX-TOOELE PERMIT HEAD SAYS JOB THREATENED TO GET COOPERATION


The former Permit Coordinator at the U.S. Army's Tooele, Utah, chemical
weapons incinerator today revealed his job was threatened unless he agreed
to submit false data and withhold vital environmental information to get
that controversial facility licensed.

Speaking at a National Press Club news conference, Gary E. Harris, said,
"Many questionable practices that were not environmentally protective, safe
or legal occurred at Tooele during my five years of employment there, and
many documents were submitted to Utah regulators by the Army and its
contractors that were dishonest or misleading. As Permit Coordinator I was
directed to submit modifications to the plant that did not comply with
Federal Law. I reported health, safety and environmental issues to the
contractor and the Army which I was directed not to bring to the attention
of the State under the threat of losing my job."

Mr. Harris provided a list of more than 100 improper activities at Tooele,
allegations he has sworn to under oath in a deposition for a Utah legal
proceeding challenging the plant's hazardous waste operating permit. Among
his specific charges:
        * Political influence was applied by the Army to "fix" Utah process
to cover-up dangerous practices and avoid public review and comment. Utah
permit did not reflect facility actually built;
        * The plant's Health Risk Assessment was politically adjusted to
obtain desired results by removal of data about people living and farming
close to the incineration facilities;
        * Incinerator trial burns were falsified to avoid revealing that
Metal Parts Furnace incinerator cannot safely burn the jelled agent found
in many munitions and containers;
        * Data was manipulated to conceal fact that agent was not staying
in Deactivation Furnace long enough to be destroyed;
        * Information was purposefully withheld from the regulators that a
key component of planned agent destruction process, the dunnage incinerator
designed to handle agent contaminated material like protective suits, could
not work;
       * Staff were directed not to incorporate "lessons learned" from
other facilities, such as the fact that the incinerators could not
completely incinerate mustard agent, into the Tooele design and not to
contact any sites under construction to share information on problems;
      * Agent residues were improperly disposed of off-site; and
      * Nearby communities never agreed to provide emergency response for
accidents as required by permit was ignored;

The Tooele chemical weapons incinerator, the only such facility on the U.S.
mainland and the model for similar plants slated for construction in
Arkansas, Oregon, Alabama, Colorado, and Kentucky has been severely
criticized by former plant officials and citizen groups. Tooele's former
Safety Manager, Steve Jones, was terminated for refusing to certify that
the facility was safe but returned to his job after the U.S. Department of
Labor found that he had been illegally fired for having raised safety and
environmental concerns. Subsequently, the plant's General Manager, Gary
Millar, resigned charging that the Tooele incinerator remained unsafe. Then
the plant's hazardous waste manager Trina Allen was forced to resign after
raising concerns about environmental violations at the facility. A
Department of Labor judge ruled in favor of Ms. Allen on her whistleblower
retaliation complaint.

Mick Harrison, the lawyer representing Mr. Harris added, "Gary Harris'
revelations demonstrate that the U.S. Army has knowingly violated the law,
covered up known dangers, and corruptly influenced state agencies to
proceed recklessly with a technology they know does not work. This is
unacceptable behavior in any circumstances, but particularly risky in the
area of chemical weapons destruction."

Craig Williams, national spokesman for the Chemical Weapons Working Group,
a coalition supporting non-incineration technologies, concluded, "The
Army's incineration program is another 'Paducah' in the making. Workers are
being exposed, dangerous agents are being emitted, and government agencies
are conspiring to cover up the mess. The Tooele plant should be shut down
immediately and construction of similar facilities halted."

- - 3 0 - -

A background kit including a chronology of problems in the Army's
incineration program, Mr. Harris' list of significant safety, health and
environmental problems at the Tooele facility, and other information is
available on request.
Elizabeth Crowe
Chemical Weapons Working Group
Non-Stockpile Chemical Weapons Citizens Coalition
(606) 986-0868
fax:  (606) 986-2695
www.cwwg.org
--============_-1264480848==_ma============
Content-Type: text/enriched; charset="us-ascii"

<bold><fontfamily><param>Times</param><bigger>CHEMICAL WEAPONS WORKING
GROUP

PO Box 467  Berea, KY 40403

606-986-7565  606-986-2695

kefwilli@acs.eku.edu   www.cwwg.org


                                    
</bigger></fontfamily></bold><fontfamily><param>Times</param><bigger><bigger>
for further information:

                                     Craig Williams  (606) 986-7565

                                     Bob Schaeffer   (941) 395-6773

                                     Mick Harrison   (606) 321-1586


for use after 1pm EST, Tues. Jan. 11, 2000 news conference

<bold>NEW WHISTLEBLOWER SAYS U.S. ARMY ENGAGED IN FRAUD, CORRUPTION;
HID ENVIRONMENTAL VIOLATIONS

TO WIN UTAH CHEM. WEAPONS INCINERATOR PERMIT;

EX-TOOELE PERMIT HEAD SAYS JOB THREATENED TO GET COOPERATION



</bold>The former Permit Coordinator at the U.S. Army's Tooele, Utah,
chemical weapons incinerator today revealed his job was threatened
unless he agreed to submit false data and withhold vital environmental
information to get that controversial facility licensed.


Speaking at a National Press Club news conference, Gary E. Harris,
said, "Many questionable practices that were not environmentally
protective, safe or legal occurred at Tooele during my five years of
employment there, and many documents were submitted to Utah regulators
by the Army and its contractors that were dishonest or misleading. As
Permit Coordinator I was directed to submit modifications to the plant
that did not comply with Federal Law. I reported health, safety and
environmental issues to the contractor and the Army which I was
directed not to bring to the attention of the State under the threat of
losing my job."


Mr. Harris provided a list of more than 100 improper activities at
Tooele, allegations he has sworn to under oath in a deposition for a
Utah legal proceeding challenging the plant's hazardous waste operating
permit. Among his specific charges:

        * Political influence was applied by the Army to "fix" Utah
process to cover-up dangerous practices and avoid public review and
comment. Utah permit did not reflect facility actually built;

        * The plant's Health Risk Assessment was politically adjusted
to obtain desired results by removal of data about people living and
farming close to the incineration facilities;

        * Incinerator trial burns were falsified to avoid revealing
that Metal Parts Furnace incinerator cannot safely burn the jelled
agent found in many munitions and containers;

        * Data was manipulated to conceal fact that agent was not
staying in Deactivation Furnace long enough to be destroyed;

        * Information was purposefully withheld from the regulators
that a key component of planned agent destruction process, the dunnage
incinerator designed to handle agent contaminated material like
protective suits, could not work;

       * Staff were directed not to incorporate "lessons learned" from
other facilities, such as the fact that the incinerators could not
completely incinerate mustard agent, into the Tooele design and not to
contact any sites under construction to share information on problems;

      * Agent residues were improperly disposed of off-site; and

      * Nearby communities never agreed to provide emergency response
for accidents as required by permit was ignored;


The Tooele chemical weapons incinerator, the only such facility on the
U.S. mainland and the model for similar plants slated for construction
in Arkansas, Oregon, Alabama, Colorado, and Kentucky has been severely
criticized by former plant officials and citizen groups. Tooele's
former Safety Manager, Steve Jones, was terminated for refusing to
certify that the facility was safe but returned to his job after the
U.S. Department of Labor found that he had been illegally fired for
having raised safety and environmental concerns. Subsequently, the
plant's General Manager, Gary Millar, resigned charging that the Tooele
incinerator remained unsafe. Then the plant's hazardous waste manager
Trina Allen was forced to resign after raising concerns about
environmental violations at the facility. A Department of Labor judge
ruled in favor of Ms. Allen on her whistleblower retaliation
complaint.


Mick Harrison, the lawyer representing Mr. Harris added, "Gary Harris'
revelations demonstrate that the U.S. Army has knowingly violated the
law, covered up known dangers, and corruptly influenced state agencies
to proceed recklessly with a technology they know does not work. This
is unacceptable behavior in any circumstances, but particularly risky
in the area of chemical weapons destruction."


Craig Williams, national spokesman for the Chemical Weapons Working
Group, a coalition supporting non-incineration technologies, concluded,
"The Army's incineration program is another 'Paducah' in the making.
Workers are being exposed, dangerous agents are being emitted, and
government agencies are conspiring to cover up the mess. The Tooele
plant should be shut down immediately and construction of similar
facilities halted."


- - 3 0 - -


A background kit including a chronology of problems in the Army's
incineration program, Mr. Harris' list of significant safety, health
and environmental problems at the Tooele facility, and other
information is available on request. </bigger></bigger></fontfamily>

Elizabeth Crowe

Chemical Weapons Working Group

Non-Stockpile Chemical Weapons Citizens Coalition

(606) 986-0868

fax:  (606) 986-2695

www.cwwg.org

--============_-1264480848==_ma============--





From Evertcc@aol.com Tue, 11 Jan 2000 17:55:04 EST
Date: Tue, 11 Jan 2000 17:55:04 EST
From: Evertcc@aol.com Evertcc@aol.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking
 water distr...

Jon, 

I understand that many PVC products contain organo-metalic compounds which 
serve as stabilizers ( I believe), hence the lead dust hazard on PVC mini 
blinds.
Any known leaching of these?

Carl





From pat.costner@dialb.greenpeace.org Tue, 11 Jan 2000 16:58:20 -0600
Date: Tue, 11 Jan 2000 16:58:20 -0600
From: pat.costner@dialb.greenpeace.org pat.costner@dialb.greenpeace.org
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinking water distribution

Dear Mr. Bell,

I posted the abstract of the study by Payment (1999).  
Subsequently, I pointed out how your interpretation of the abstract 
differed, in very important and fundamental ways, from the wording 
of the abstract itself.  I.e., you misread and/or misinterpreted the 
abstract.  Also, your last question below suggests that continuing to 
pursue this discussion will not be productive.  Comprehension is a 
matter of attention and practice; it is rarely directly imparted.  

My kind regards,

Pat Costner

On 11 Jan 00, at 19:00, david bell wrote:
Re: [Dioxin-l] Re: Poor efficacy of residual chlo

> Hi Pat
> perhaps you can explain the wording of the abstract to me: I have not seen
> the paper, and do not know what information it contains.
> 
> >microorganisms remained relatively
> >     unaffected in water from the distribution systems tested
> 
> I understand this-
> 
> >except for Escherichia coli
> 
> Can you please explain to me what this means ? Does this not mean that E
> coli is affected by water from the distribution systems tested ? Is this
> not the wording of the abstract ?
> 
> If E coli is disinfected, is this not a good thing ?
> 
> If other bacteria and viruses are not inactivated, that is clearly a 'bad
> thing'; but you don't make the 'bad thing' better by adding another
> pathogen, E coli, to the mix.
> 
> david
> 
> >Dear Mr. Bell,
> >
> >I urge you to give the abstract of the study by Payment (1999)  a
> >more careful reading.  You have interpreted it to say that "E coli is
> >inactivated by residual chlorine throughout the distribution system." 
> >This differs considerably from the actual wording of the abstract, as
> >follows:
> >
> >     "Except for Escherichia coli, microorganisms remained relatively
> >     unaffected in water from the distribution systems tested. When
> >     sewage was added to the water samples, indigenous thermotolerant
> >     coliforms were inactivated only when water was obtained from sites
> >     very close to the treatment plant and containing a high residual
> >     chlorine concentration."
> >
> >You then note, " Given that E coli is a principal contaminant of
> >sewage (and in turn the water supply system), and can be highly
> >pathogenic (eg E coli 0157), this abstract can easily be used to
> >  make a case for chlorination of water supplies."   With this, I
> >  would suggest that you have missed a major finding of the study:
> >
> >     "Clostridium perfringens was barely inactivated, suggesting that the
> >     most resistant pathogens such as Giardia lamblia, Cryptosporidium
> >     parvum, and human enteric viruses would not
> >    be inactivated. "
> <snip>
> ______________________________________________________
> Get Your Private, Free Email at http://www.hotmail.com
> 
> 
> 
> _______________________________________________
> Dioxin-l mailing list
> Dioxin-l@lists.essential.org
> http://lists.essential.org/mailman/listinfo/dioxin-l
> 


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
Greenpeace
P.O. Box 548
 or 512 County Road 2663
Eureka Springs, Arkansas 72632
ph: 1 501 253 8440
fx: 1 501 253 5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~





From superjicb@email.msn.com Tue, 11 Jan 2000 17:58:13 -0800
Date: Tue, 11 Jan 2000 17:58:13 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Re:Reply

Tony,

Maybe I'm not explaining what I think clearly enough.  Also maybe after
working almost 15 years altogether in the chemical industry (two firms)
there are concepts that I did not question that I should have questioned.
I've monitored this board for a long time without comment.  I only commented
because I found David so outrageous.  Trust that the intent of my posts were
pro human health (and therefore pro environmental health).

Drawing my data from published sources, in the US today we use about 4% of
chlorine for water treatment, and most of the 4% is for primary and
secondary water treatment.  My guess is that about 5% of the 4% is used in
residual water treatment. Multiplying the number out shows that I was
indicating that it could be necessary to continue to use .2% of all chlorine
made intentionally in the US for the purpose of residual water treatment.
That is a fifth of one percent.  I said this because I personally did not
know of any viable replacement for chlorine in residual treatment, and it
was my understanding that residual treatment is necessary for human health.
Over the years I cannot tell you how often I read and heard that
environmental advocates were fanatics for wanting to ban chlorine from water
treatment.  One way to stop this undeserved bad press is to concede using
chlorine where it makes sense.  If I'm wrong about my belief that chlorine
is needed for residual water treatment, then fine, help me learn. If I am
right, then it is my belief that environmental advocates should support
chlorine in this tiny application, while they look for safer alternatives.
Sometimes you need to be willing to lose a battle to win the war, especially
where human health is at stake, and when perception is an important
consideration, and when your educational budget is a small percent of their
PR and lobbying budgets.

PVC end uses are no mystery and I do not personally know of any uses where
PVC is a must-have.  If special uses exist, I imagine that they would
require a fraction of a percent of today's PVC demand (and that means an
even smaller fraction of a percent of today's chlorine demand).  In my
opinion PVC pipes, siding, car panels, etc., are not needed and all should
go.

For the last two years I've only followed environmental issues as a passive
observer, but David's statements were so defeating, that they outraged me to
comment, albeit without the data needed to refute much of what he had to
say.   If I'm wrong David, please let us know who you work for and what your
position is and why you asked these specific questions.

I'm the kind of person who needs to read it myself to believe it.   I had no
information to deny David's indication that dioxin levels in the US are
already well in excess of what the EPA has determined we can tolerate.  But
I found it suspect that David's questions indicated that the cost of
decreasing dioxin may not be worth the effort because nature makes more
chlorine than the EPA finds tolerable  -- yes David - logic tells us that if
you indicate that late 1800s dioxin levels are natural because there was no
industry at that time, and you combine this concept with the concept that
you held forth that dioxin is already way over EPA acceptable levels, then
you are indicating that NATURE makes more chlorine than the US EPA finds
tolerable.  I wondered if this was just your personal view or if industry
was propagating it, but even without data, plain old logic told me that if I
accept that we have moved beyond safe levels of dioxin in our environment,
that it becomes even more urgent to immediately stop producing more dioxin.

Tony, I want to make it clear to you that while I can now see your point,
that my statement was proffered to debate Davids, not to imply that dioxin
is safe at some specific level.  I'd like to imagine that I think for
myself, but I recognize that altogether I worked about 15 years in the
chemical industry and that I've been inundated with the idea that "the dose
makes the difference."   I never saw a problem with accepting this concept
until you questioned my motives.  You wrote: "Other posts from these people
have similarly been couched in reasonable sounding arguments but were
actually quite radical arguments--eg that dioxin in the env is safe if at a
certain level."  This obviously questioned my motives and at first I was
upset because my motives were on the side of human health, but then I calmed
down and starting thinking about it.

Dose normally refers to medicine or cures, but in general terms industry
tends to use it to include toxins.  Therefore, the question posed by
industry is more or less: "at what level is a dose of poison acceptable." I
accept that it is difficult to give credibility to any specific number,
especially because scientists change their mind so often, and have such
disparate views.  Also, when you combine science with politics - which is
what the EPA is all about, you must factor in ulterior motives.  And how do
you do this?  If you assume that at a point in time the EPA is pro-industry,
then you recognize that they can benefit industry by saying (for example)
that intolerable levels are any level greater than 1, but that today we are
only at .006 so we don't have to worry.  Or they can say that intolerable
levels are 1 but nature produces 1,000 - so the situation is helpless --
which seemed to me to be David's message, and I found the message
intolerable - David correct me if I am wrong.

Considering all factors, the only thing that makes sense to me is that we
accept the amount of dioxin that nature makes, as the maximum tolerable
level, and that we are therefore very careful to ensure that we work hard
towards making sure that we make NONE ourselves.  I say this because poison
is poison, and there are too many variables to consider, and about the only
thing that we can count on is that we can measure how much there is right
now and "maybe" compare that to what used to be.  I say "maybe" when I refer
to historical samples, because we determine historical levels by digging
holes in the ground to certain depths, and taking samples from what we
believe are levels of historical significance.  The problem with these
samples is that the dioxin in the sample may have been formed sometime after
the historical period that we believe the sample came from.  Or maybe there
was MORE dioxin present at the time of historical significance and over time
the dioxin that had been present broke down, which would lead us to believe
that there was less dioxin present in the past than there really was.
Either way the only thing we can be sure of is that we really don't know.
All we know is that any species that cannot survive in nature dies out, and
that we are still around.

Making core sample slides for oil exploration was something that I did to
put myself through college.  I have since observed that if man could really
depend on the chemistry of core samples, man would not be drilling so many
dry wells.  The only one thing we know for sure about nature and dioxin is
that so far nature has been kind, and has not made more dioxin than man can
tolerate.  I'm personally grateful for this and I think we all should be
grateful.  The one thing we can say about man, is that logic leads us to
believe that man has made more dioxin than man can tolerate.

Tony, I hope this has clarified my position and that I've redeemed myself
from being included as one of "these people."

Connie Hansson

From: Tony Tweedale <ttweed@wildrockies.org>
> Some posts from these people have been logical, others not.  >








From carllark@olypen.com Tue, 11 Jan 2000 18:13:56 -0800
Date: Tue, 11 Jan 2000 18:13:56 -0800
From: Carl Larkins carllark@olypen.com
Subject: [Dioxin-l] Reply

This is a multi-part message in MIME format.

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Greetings All,

in spite of my resolve not to get draged into this, I am in.  I
offer the comments shown below.

Carl Larkins
  ----- Original Message -----
  From: superjicb
  To: dioxin-l@lists.essential.org
  Sent: Monday, January 10, 2000 9:22 AM
  Subject: [Dioxin-l] Reply


  David,
  Your comment:

  > One of the interesting things is that erring on the side of
caution can have its costs. So currently, the US EPA estimates
daily intake of dioxin TEQs as 1-4 ng/kg, or 100-400 times
greater than the EPA recommended intake. It is not clear how
one would get the level of dioxin TEQ intake down by 400 fold;
it would certainly be an expensive undertaking. Some estimates
are that it would cost in excess of the US GNP to reduce dioxin
intakes to the US EPA
  recommended levels; clearly you would only want to spend that
money if there were to be a tangible benefit.

  My reply:

  One of the interesting things is that erring on the side of
risk can have is costs, both to human health, shorter life
spans, and to the economy in the form of high medical bills,
lost productivity, etc.  I cannot comment on the validity of
the EPAs numbers but plain old common sense tells me that here
we are not even talking about erring on the side of risk.  If
scientists already think our dioxin intake is too high, then we
are talking about blatent disregard. This only makes it more
urgent that we move quickly to do what we can to stop from
increasing dioxin levels even further.  The answer is not to
throw up our hands and give up.
  =============================================

  My comment:

  If there have been benifits from products that spawn dioxin,
those benificaries should bear the cost of any harm caused by
dioxin and
   the cost of preventing dioxin from causing additional harm.
Especially in those cases where alternatives exist, stock
hoders and others who reap chlorine profits are passing dioxin
related costs on to future generations.

  =============================================


  Your comment:
  > > > Given the recent postings about production of dioxins
from uncontrolled burning, it may well be that the level of
dioxin in the 1800s largely stemmed from the incineration that
the local populace undertook. It clearly wasn't the chemical
industry.

   My initial reply:
  > >Why is it clear chemicals were not implicated?

   Your reply:
  > There was next to no organochlorine chemical industry in
the late 1800s, and
  > precious little in America. Compare with hundreds of
millions of tons of
  > organochlorines produced in the 60s; as far as I am aware,
there wasn't the
  > technology to make, transport or a market to sell a million
tons of
  > organochlorine compound in the 1800s. So where did the
environmental dioxin
  > production come from in the 1800s? It still amounted to 10%
of current
  > levels. I guess I can only think of uncontrolled burning;
all suggestions
  > welcome.

  My reply:

  I can come up with a reason other than uncontrolled burning
that would implicate chlorine.  When we talked about dioxin in
the late 1800s it was related to the Beaver Lake dioxin in
sludge study that you brought to our attention.  We all know
chemical pulping occurs on large bodies of water.  I think we
both agreed that the mid 1950s dioxin contamination of this
lake likely came from chlorine bleaching of pulp.   What is in
contention is what occurred early on.  Successful chemical
pulping began in about 1851 and to the best of my knowledge,
pulp was bleached with chlorine even before chemical pulping
became the standard.  In the early 1800s British scientists
already knew how to produce chlorine electrochemically, but
because electricity was so expensive electrochemical chlorine
production did not occur until the 1900s, and in the 1800s
commercial chloirne was produced by oxidation of HCl with
manganese dioxide or air.  I expect we'd all agree that early
pulping and bleaching was done with nearly total disregard for
the environment (not intentional disregard, but because
industry was likely unaware of the problem brewing).   I don't
know the size of Beaver Lake, or how many if any mills it
supported, or if there was a chlorine plant on site to support
pulp bleaching, but logic suggests the whole thing is related
to pulp bleaching.  You brought up this study as evidence of
some point.  Would you please let us know what industry was on
this lake and when, so we can draw some intelligent conclusion
from the data?

  Connie
  ================================
  My comment:

  Some of the recent postingson back yard burning are based on
test results that are skewed.
  *The majority of backyard burning occurs in rural areas, but
the assumed contents of the burn barrel are based on studies
from urban areas.
  *Conclusions were based on an incinerator based on a
destruction and removal efficiency that is rarely achieved (not
even during demonstration burns) with an unstated assumed fuel
mix that may or maynot be similar to that in the hypothetical
barrel.
  *The study report was published (sponsored by?) the Journal
of the American chemical Society.
  ===============================
  In response to the suggestion in the study report that the
"study could help resolve a long-standing discrepany as a
result of a 1994 EPA   assesment that identified a "significant
gap" between estimates of dioxin estimates and actual
deposition measurements...";
  I would suggest that EPA look at a source that they have
carefully ignored: The dioxins produced in wood-fired boilers
that include sludge and salty hogged fuel in their fuel mix.


  Carl Larkins

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<HTML><HEAD>
<META content=3D"text/html; charset=3Diso-8859-1" =
http-equiv=3DContent-Type>
<META content=3D"MSHTML 5.00.2314.1000" name=3DGENERATOR>
<STYLE></STYLE>
</HEAD>
<BODY bgColor=3D#fffff0>
<DIV>Greetings All,</DIV>
<DIV>&nbsp;</DIV>
<DIV>in spite of my resolve not to get draged into this, I am in.&nbsp; =
I offer=20
the comments shown below.</DIV>
<DIV>&nbsp;</DIV>
<DIV>Carl Larkins</DIV>
<BLOCKQUOTE=20
style=3D"BORDER-LEFT: #000000 2px solid; MARGIN-LEFT: 5px; MARGIN-RIGHT: =
0px; PADDING-LEFT: 5px; PADDING-RIGHT: 0px">
  <DIV style=3D"FONT: 10pt arial">----- Original Message ----- </DIV>
  <DIV=20
  style=3D"BACKGROUND: #e4e4e4; FONT: 10pt arial; font-color: =
black"><B>From:</B>=20
  <A href=3D"mailto:superjicb@email.msn.com"=20
  title=3Dsuperjicb@email.msn.com>superjicb</A> </DIV>
  <DIV style=3D"FONT: 10pt arial"><B>To:</B> <A=20
  href=3D"mailto:dioxin-l@lists.essential.org"=20
  title=3Ddioxin-l@lists.essential.org>dioxin-l@lists.essential.org</A> =
</DIV>
  <DIV style=3D"FONT: 10pt arial"><B>Sent:</B> Monday, January 10, 2000 =
9:22=20
  AM</DIV>
  <DIV style=3D"FONT: 10pt arial"><B>Subject:</B> [Dioxin-l] Reply</DIV>
  <DIV><BR></DIV>
  <DIV><FONT face=3DArial size=3D2>David, </DIV>
  <P class=3DMsoNormal>Your comment:</P>
  <P class=3DMsoNormal>&gt; One of the interesting things is that erring =
on the=20
  side of caution can have its costs. So currently, the US EPA estimates =
daily=20
  intake of dioxin TEQs as 1-4 ng/kg, or 100-400 times greater than the =
EPA=20
  recommended intake. It is not clear how one would get the level of =
dioxin TEQ=20
  intake down by 400 fold; it would certainly be an expensive =
undertaking. Some=20
  estimates are that it would cost in excess of the US GNP to reduce =
dioxin=20
  intakes to the US EPA <BR>recommended levels; clearly you would only =
want to=20
  spend that money if there were to be a tangible benefit.</P>
  <P class=3DMsoNormal>My reply:</P>
  <P class=3DMsoNormal>One of the interesting things is that erring on =
the side of=20
  risk can have is costs, both to human health, shorter life spans, and =
to the=20
  economy in the form of high medical bills, lost productivity, =
etc.&nbsp; I=20
  cannot comment on the validity of the EPAs numbers but plain old =
common sense=20
  tells me that here we are not even talking about erring on the side of =

  risk.&nbsp; If scientists already think our dioxin intake is too high, =
then we=20
  are talking about blatent disregard.&nbsp;This only makes it more =
urgent that=20
  we move quickly to do what we can to stop from increasing dioxin =
levels even=20
  further.&nbsp; The answer is not to throw up our hands and give =
up.&nbsp;=20
  <BR><FONT =
size=3D2>=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D</FO=
NT></P>
  <P class=3DMsoNormal><FONT size=3D2>My comment:</FONT></P>
  <P class=3DMsoNormal>If there have been benifits from products that =
spawn=20
  dioxin, those benificaries should bear the cost of any harm caused by =
dioxin=20
  and<BR><FONT size=3D2> the cost of preventing dioxin from causing =
additional=20
  harm.&nbsp;&nbsp; Especially in those cases where alternatives exist, =
stock=20
  hoders and others who reap chlorine profits are passing dioxin related =
costs=20
  on to future generations.</FONT></P>
  <P =
class=3DMsoNormal>=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D</P>
  <P class=3DMsoNormal><BR>Your comment:<BR>&gt; &gt; &gt; Given the =
recent=20
  postings about production of dioxins from uncontrolled burning, it may =
well be=20
  that the level of dioxin in the 1800s largely stemmed from the =
incineration=20
  that the local populace undertook. It clearly wasn't the chemical=20
industry.</P>
  <P class=3DMsoNormal>&nbsp;My initial reply:<BR>&gt; &gt;Why is it =
clear=20
  chemicals were not implicated?</P>
  <P class=3DMsoNormal>&nbsp;Your reply:<BR>&gt; There was next to no=20
  organochlorine chemical industry in the late 1800s, and <BR>&gt; =
precious=20
  little in America. Compare with hundreds of millions of tons of =
<BR>&gt;=20
  organochlorines produced in the 60s; as far as I am aware, there =
wasn't the=20
  <BR>&gt; technology to make, transport or a market to sell a million =
tons of=20
  <BR>&gt; organochlorine compound in the 1800s. So where did the =
environmental=20
  dioxin <BR>&gt; production come from in the 1800s? It still amounted =
to 10% of=20
  current <BR>&gt; levels. I guess I can only think of uncontrolled =
burning; all=20
  suggestions <BR>&gt; welcome.</P>
  <P class=3DMsoNormal>My reply:</P>
  <P class=3DMsoNormal>I can come up with a reason other than =
uncontrolled burning=20
  that would implicate chlorine.&nbsp; When we talked about dioxin in =
the late=20
  1800s it was related to the Beaver Lake dioxin in sludge study that =
you=20
  brought to our attention.&nbsp; We all know chemical pulping occurs on =
large=20
  bodies of water.<SPAN style=3D"mso-spacerun: yes">&nbsp; </SPAN>I =
think we both=20
  agreed that the mid 1950s dioxin contamination of this lake likely =
came from=20
  chlorine bleaching of pulp.&nbsp;&nbsp; What is in contention is what =
occurred=20
  early on.&nbsp; Successful chemical pulping began in about 1851 and to =
the=20
  best of my knowledge, pulp was bleached with chlorine even before =
chemical=20
  pulping became the standard.<SPAN style=3D"mso-spacerun: yes">&nbsp; =
In the=20
  early 1800s British scientists already knew how to produce chlorine=20
  electrochemically, but because electricity was so expensive =
electrochemical=20
  chlorine production did not occur until the 1900s, and in the 1800s =
commercial=20
  chloirne was produced by oxidation of HCl with manganese dioxide or =
air.&nbsp;=20
  I expect we'd all agree that </SPAN>early pulping and bleaching was =
done with=20
  nearly total disregard for the environment (not intentional disregard, =
but=20
  because industry was likely unaware of the problem brewing). <SPAN=20
  style=3D"mso-spacerun: yes">&nbsp;&nbsp;I</SPAN> don't know the size =
of Beaver=20
  Lake, or how many if any mills it supported, or if there was a =
chlorine plant=20
  on site to support pulp bleaching, but logic suggests the whole thing =
is=20
  related to pulp bleaching.&nbsp; You brought up this study as evidence =
of some=20
  point.&nbsp; Would you please let us know what industry was on this =
lake and=20
  when, so we can draw some intelligent conclusion from the data?</P>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">Connie</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">My=20
  comment:</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN>&nbsp;</DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">Some=20
  of the recent postingson back yard burning are based on test results =
that are=20
  skewed.</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*The=20
  majority of backyard burning occurs in rural areas, but the assumed =
contents=20
  of the burn barrel are based on studies from urban areas.</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*Conclusions=20
  were based on an incinerator based on a destruction and removal =
efficiency=20
  that is rarely achieved (not even during demonstration burns) with an =
unstated=20
  assumed fuel mix that may or maynot be similar to that in the =
hypothetical=20
  barrel.</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*The=20
  study report was published (sponsored by?) the Journal of the American =

  chemical Society.</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">In=20
  response to the suggestion in the study report that the "study could =
help=20
  resolve a long-standing discrepany as a result of a 1994=20
  EPA&nbsp;&nbsp;&nbsp;assesment that identified a "significant gap" =
between=20
  estimates of dioxin estimates and actual deposition=20
  measurements...";</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">I=20
  would suggest that EPA look at a source that they have carefully =
ignored: The=20
  dioxins produced in wood-fired boilers that include sludge and salty =
hogged=20
  fuel in their fuel mix.</SPAN></DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN>&nbsp;</DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN>&nbsp;</DIV>
  <DIV><SPAN=20
  style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">Carl=20
  Larkins</SPAN></FONT></DIV></BLOCKQUOTE></BODY></HTML>

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From jon@cqs.com Tue, 11 Jan 2000 22:53:22 -0500
Date: Tue, 11 Jan 2000 22:53:22 -0500
From: Jon Campbell jon@cqs.com
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in drinkingwater distr...

Carl,

      I'm not aware of any lead leaching in PVC water tubing, but then again
I don't know whether they use lead or other metals in tubing. The whole lead
issue was a new one to me a couple of years ago, when Greenpeace blew the
whistle on it for baby toys; since then I have become aware that it is used
in wire covering and seat covers.

     Pat, do you know anything about this?

Regards
Jon
----- Original Message -----
From: <Evertcc@aol.com>
To: <dioxin-l@venice.essential.org>
Sent: Tuesday, January 11, 2000 5:55 PM
Subject: Re: [Dioxin-l] Re: Poor efficacy of residual chlorine in
drinkingwater distr...


> Jon,
>
> I understand that many PVC products contain organo-metalic compounds which
> serve as stabilizers ( I believe), hence the lead dust hazard on PVC mini
> blinds.
> Any known leaching of these?
>
> Carl
>
>
> _______________________________________________
> Dioxin-l mailing list
> Dioxin-l@lists.essential.org
> http://lists.essential.org/mailman/listinfo/dioxin-l
>






From jon@cqs.com Tue, 11 Jan 2000 23:19:23 -0500
Date: Tue, 11 Jan 2000 23:19:23 -0500
From: Jon Campbell jon@cqs.com
Subject: [Dioxin-l] Re:Reply

Connie,

      David's disruption of the list has put people on edge, and people
start questioning each other's motives. That is too bad, we all need to be
focusing on stopping dioxin exposure, not questioning each other. I'm sure
you meant well and were as outraged at David's postings as many of us have
been.

      I can't speak for Tony, but I believe there was a discussion of the
chlorine disinfectant issue on the list quite a while ago. In any case, Pat
Costner's latest posting on the issue should have set to rest the notion
that chlorine is a good water disinfectant. Its efficacy is a popular myth
that is continued by the chlorine industry. This is not much different than
triple-bypass surgery for heart disease, mercury amalgam fillings for teeth,
fluoride in water, AZT for AIDS, chemotherapy and radiation for cancer, and
any of a number of other "accepted" practices. Drill down just a few
millimeters below the surface and you find they're statistical (or outright)
shams. That is the nature of true scientific discovery on the part of
ordinary people: we come experts, leaving the physicians and corporate
researchers (whose income derives from those "accepted practices" and their
corporate promoters) way behind.

Cheers and regards
Jon
----- Original Message -----
From: "superjicb" <superjicb@email.msn.com>
To: <dioxin-l@venice.essential.org>; "Tony Tweedale"
<ttweed@wildrockies.org>
Sent: Tuesday, January 11, 2000 8:58 PM
Subject: Re: [Dioxin-l] Re:Reply


> Tony,
>
> Maybe I'm not explaining what I think clearly enough.  Also maybe after
> working almost 15 years altogether in the chemical industry (two firms)
> there are concepts that I did not question that I should have questioned.
> I've monitored this board for a long time without comment.  I only
commented
> because I found David so outrageous.  Trust that the intent of my posts
were
> pro human health (and therefore pro environmental health).
>
> Drawing my data from published sources, in the US today we use about 4% of
> chlorine for water treatment, and most of the 4% is for primary and
> secondary water treatment.  My guess is that about 5% of the 4% is used in
> residual water treatment. Multiplying the number out shows that I was
> indicating that it could be necessary to continue to use .2% of all
chlorine
> made intentionally in the US for the purpose of residual water treatment.
> That is a fifth of one percent.  I said this because I personally did not
> know of any viable replacement for chlorine in residual treatment, and it
> was my understanding that residual treatment is necessary for human
health.
> Over the years I cannot tell you how often I read and heard that
> environmental advocates were fanatics for wanting to ban chlorine from
water
> treatment.  One way to stop this undeserved bad press is to concede using
> chlorine where it makes sense.  If I'm wrong about my belief that chlorine
> is needed for residual water treatment, then fine, help me learn. If I am
> right, then it is my belief that environmental advocates should support
> chlorine in this tiny application, while they look for safer alternatives.
> Sometimes you need to be willing to lose a battle to win the war,
especially
> where human health is at stake, and when perception is an important
> consideration, and when your educational budget is a small percent of
their
> PR and lobbying budgets.
>
> PVC end uses are no mystery and I do not personally know of any uses where
> PVC is a must-have.  If special uses exist, I imagine that they would
> require a fraction of a percent of today's PVC demand (and that means an
> even smaller fraction of a percent of today's chlorine demand).  In my
> opinion PVC pipes, siding, car panels, etc., are not needed and all should
> go.
>
> For the last two years I've only followed environmental issues as a
passive
> observer, but David's statements were so defeating, that they outraged me
to
> comment, albeit without the data needed to refute much of what he had to
> say.   If I'm wrong David, please let us know who you work for and what
your
> position is and why you asked these specific questions.
>
> I'm the kind of person who needs to read it myself to believe it.   I had
no
> information to deny David's indication that dioxin levels in the US are
> already well in excess of what the EPA has determined we can tolerate.
But
> I found it suspect that David's questions indicated that the cost of
> decreasing dioxin may not be worth the effort because nature makes more
> chlorine than the EPA finds tolerable  -- yes David - logic tells us that
if
> you indicate that late 1800s dioxin levels are natural because there was
no
> industry at that time, and you combine this concept with the concept that
> you held forth that dioxin is already way over EPA acceptable levels, then
> you are indicating that NATURE makes more chlorine than the US EPA finds
> tolerable.  I wondered if this was just your personal view or if industry
> was propagating it, but even without data, plain old logic told me that if
I
> accept that we have moved beyond safe levels of dioxin in our environment,
> that it becomes even more urgent to immediately stop producing more
dioxin.
>
> Tony, I want to make it clear to you that while I can now see your point,
> that my statement was proffered to debate Davids, not to imply that dioxin
> is safe at some specific level.  I'd like to imagine that I think for
> myself, but I recognize that altogether I worked about 15 years in the
> chemical industry and that I've been inundated with the idea that "the
dose
> makes the difference."   I never saw a problem with accepting this concept
> until you questioned my motives.  You wrote: "Other posts from these
people
> have similarly been couched in reasonable sounding arguments but were
> actually quite radical arguments--eg that dioxin in the env is safe if at
a
> certain level."  This obviously questioned my motives and at first I was
> upset because my motives were on the side of human health, but then I
calmed
> down and starting thinking about it.
>
> Dose normally refers to medicine or cures, but in general terms industry
> tends to use it to include toxins.  Therefore, the question posed by
> industry is more or less: "at what level is a dose of poison acceptable."
I
> accept that it is difficult to give credibility to any specific number,
> especially because scientists change their mind so often, and have such
> disparate views.  Also, when you combine science with politics - which is
> what the EPA is all about, you must factor in ulterior motives.  And how
do
> you do this?  If you assume that at a point in time the EPA is
pro-industry,
> then you recognize that they can benefit industry by saying (for example)
> that intolerable levels are any level greater than 1, but that today we
are
> only at .006 so we don't have to worry.  Or they can say that intolerable
> levels are 1 but nature produces 1,000 - so the situation is helpless --
> which seemed to me to be David's message, and I found the message
> intolerable - David correct me if I am wrong.
>
> Considering all factors, the only thing that makes sense to me is that we
> accept the amount of dioxin that nature makes, as the maximum tolerable
> level, and that we are therefore very careful to ensure that we work hard
> towards making sure that we make NONE ourselves.  I say this because
poison
> is poison, and there are too many variables to consider, and about the
only
> thing that we can count on is that we can measure how much there is right
> now and "maybe" compare that to what used to be.  I say "maybe" when I
refer
> to historical samples, because we determine historical levels by digging
> holes in the ground to certain depths, and taking samples from what we
> believe are levels of historical significance.  The problem with these
> samples is that the dioxin in the sample may have been formed sometime
after
> the historical period that we believe the sample came from.  Or maybe
there
> was MORE dioxin present at the time of historical significance and over
time
> the dioxin that had been present broke down, which would lead us to
believe
> that there was less dioxin present in the past than there really was.
> Either way the only thing we can be sure of is that we really don't know.
> All we know is that any species that cannot survive in nature dies out,
and
> that we are still around.
>
> Making core sample slides for oil exploration was something that I did to
> put myself through college.  I have since observed that if man could
really
> depend on the chemistry of core samples, man would not be drilling so many
> dry wells.  The only one thing we know for sure about nature and dioxin is
> that so far nature has been kind, and has not made more dioxin than man
can
> tolerate.  I'm personally grateful for this and I think we all should be
> grateful.  The one thing we can say about man, is that logic leads us to
> believe that man has made more dioxin than man can tolerate.
>
> Tony, I hope this has clarified my position and that I've redeemed myself
> from being included as one of "these people."
>
> Connie Hansson
>
> From: Tony Tweedale <ttweed@wildrockies.org>
> > Some posts from these people have been logical, others not.  >
>
>
>
>
>
> _______________________________________________
> Dioxin-l mailing list
> Dioxin-l@lists.essential.org
> http://lists.essential.org/mailman/listinfo/dioxin-l
>






From carllark@olypen.com Tue, 11 Jan 2000 19:44:56 -0800
Date: Tue, 11 Jan 2000 19:44:56 -0800
From: Carl Larkins carllark@olypen.com
Subject: [Dioxin-l] Reply

Be careful. Under given circumstances, some congeners degrade more
rapidlym than others, plus, we Know nothing about the breakdown
process.  Does a highly chlorinated conger break down to ??

Carl Larkins

----- Original Message -----
From: Henshel, Diane S. <dhenshel@indiana.edu>
To: 'superjicb ' <superjicb@email.msn.com>;
<dioxin-l@lists.essential.org>
Sent: Monday, January 10, 2000 4:49 PM
Subject: RE: [Dioxin-l] Reply


: It seems to me the argument below could be settled with congener
analysis.
: Since incineration produces primarily the PCDFs and relatively
little TCDD,
: it should have a clear chemical signature very distinct from the
chemical
: signature released by kraft pulp bleaching processes, in which
there is a
: high percentage of TCDD contamination.
: Has anyone got the congener data?
:
: Your comment:
: > > > Given the recent postings about production of dioxins from
: uncontrolled burning, it may well be that the level of dioxin in
the
: 1800s largely stemmed from the incineration that the local
populace
: undertook. It clearly wasn't the chemical industry.
:
:  My initial reply:
: > >Why is it clear chemicals were not implicated?
:
:  Your reply:
: > There was next to no organochlorine chemical industry in the
late
: 1800s, and
: > precious little in America. Compare with hundreds of millions
of tons
: of
: > organochlorines produced in the 60s; as far as I am aware,
there
: wasn't the
: > technology to make, transport or a market to sell a million
tons of
: > organochlorine compound in the 1800s. So where did the
environmental
: dioxin
: > production come from in the 1800s? It still amounted to 10% of
current
:
: > levels. I guess I can only think of uncontrolled burning; all
: suggestions
: > welcome.
:
: My reply:
:
: I can come up with a reason other than uncontrolled burning that
would
: implicate chlorine.  When we talked about dioxin in the late
1800s it
: was related to the Beaver Lake dioxin in sludge study that you
brought
: to our attention.  We all know chemical pulping occurs on large
bodies
: of water.  I think we both agreed that the mid 1950s dioxin
: contamination of this lake likely came from chlorine bleaching of
pulp.
: What is in contention is what occurred early on.  Successful
chemical
: pulping began in about 1851 and to the best of my knowledge, pulp
was
: bleached with chlorine even before chemical pulping became the
standard.
: In the early 1800s British scientists already knew how to produce
: chlorine electrochemically, but because electricity was so
expensive
: electrochemical chlorine production did not occur until the
1900s, and
: in the 1800s commercial chloirne was produced by oxidation of HCl
with
: manganese dioxide or air.  I expect we'd all agree that early
pulping
: and bleaching was done with nearly total disregard for the
environment
: (not intentional disregard, but because industry was likely
unaware of
: the problem brewing).   I don't know the size of Beaver Lake, or
how
: many if any mills it supported, or if there was a chlorine plant
on site
: to support pulp bleaching, but logic suggests the whole thing is
related
: to pulp bleaching.  You brought up this study as evidence of some
point.
: Would you please let us know what industry was on this lake and
when, so
: we can draw some intelligent conclusion from the data?
:
: Connie
:
:
: _______________________________________________
: Dioxin-l mailing list
: Dioxin-l@lists.essential.org
: http://lists.essential.org/mailman/listinfo/dioxin-l
:






From superjicb@email.msn.com Wed, 12 Jan 2000 10:19:39 -0800
Date: Wed, 12 Jan 2000 10:19:39 -0800
From: superjicb superjicb@email.msn.com
Subject: [Dioxin-l] Re:Reply

TO ALL -

Regarding my statement:
"nature makes more chlorine than the EPA finds tolerable  -- yes David -
logic tells us that if you indicate that late 1800s dioxin levels are
natural because there was no industry at that time, and you combine this
concept with the concept that you held forth that dioxin is already way over
EPA acceptable levels, then you are indicating that NATURE makes more
chlorine than the US EPA finds tolerable."

Of course this was incorrect -- I meant to say it meant nature makes more
DIOXIN than EPA finds tolerable, not more chlorine.

Connie







From ntangri@essential.org Wed, 12 Jan 2000 11:37:59 -0500
Date: Wed, 12 Jan 2000 11:37:59 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] R.P. case bares inadequacy of waste rules

http://www.yomiuri.co.jp/index-e.htm


      January 12, 2000

                Govt begins unloading batch of waste returned from R.P.

                Yomiuri Shimbun

                A government-chartered vessel carrying a large amount of

                garbage--including hazardous hospital waste that was
illegally exported to
                the Philippines by a Japanese company--arrived in Tokyo
on Tuesday, and
                workers began unloading the 122 containers at Oi Pier.

                Police will soon launch a full-scale investigation into
the garbage shipment
                that is believed to be a violatation of the Basel
Convention on the shipment
                of hazardous waste.

                It is the first time that the government has recovered
such waste since the
                international convention came into effect eight years
ago.

                The government will likely pay the 60 million yen
transportation cost and
                other costs, such as incineration expenses, which will
total more than 100
                million yen, for Nisso Ltd., an industrial waste
disposal company located in
                Oyama, Tochigi Prefecture, as the company president is
reportedly missing.

                The MV Pulsar that transported the waste docked at about

7:20 a.m., and
                officials from the International Trade and Industry
Ministry and the
                Environment Agency were present at the unloading.
Investigators from the
                Tochigi and Nagano prefectural police confirmed the
arrival of the
                containers. The containers weighed about 2,700 tons in
total.

                Ayako Sekine, 31, a member of Greenpeace Japan, who was
watching the
                containers being unloaded at the pier said she was
ashamed about the
                garbage shipment to the Philippines because it caused
"profound distrust
                toward Japan in the international community."

                "The government should strengthen its supervision to
prevent such an
                incident from being repeated," she said. "Our
organization will continue to
                monitor the disposal of the waste."

                The Health and Welfare Ministry, the Environment Agency
and MITI issued
                orders to Nisso, at about 11 a.m., to correctly dispose
of the garbage.

                Tuesday was the deadline for the government to recover
the garbage under
                the Basel Convention. The government received an
official report from the
                Philippine government about the illegal shipment in
December.

                The government sent inspectors to the Philippines to
investigate the claim,
                and they confirmed that the garbage contained infectious

hospital waste such
                as used hypodermic needles and containers of intravenous

drips. The
                government then ordered Nisso to recover the garbage
while accusing it of
                violating the Foreign Exchange and Foreign Trade Control

Law on Dec. 24.

                An Environment Agency official said, "We had to act
promptly as a
                Philippine newspaper wrote that the shipment was
'Japan's third invasion
                following the war and economic invasion.' Otherwise, it
would have become
                a serious diplomatic issue."

                Mitsuo Ohashi, chairman of secretariat of the Japan
Network on the Waste
                Landfill, said, "Developing countries tend to be
targeted as a destination for
                garbage in the name of recycling because their
environmental regulations are
                less strict and labor costs are cheaper than those in
Japan. We should see
                the latest incident as the tip of the iceberg."

                Police find illegal dumping

                The joint investigation headquarters of the Tochigi and
Nagano prefectural
                police will in a few days start inspecting the recovered

garbage on suspicion
                that its export violated the Foreign Exchange and
Foreign Trade Control
                Law.

                The headquarters also plans to request a warrant of
arrest against Hiromi
                Ito, 49, the president of the industrial waste disposal
company, after
                searching the company's office and storage facilities.

                According to the joint investigation team, Ito bought a
building materials
                company in Oyama in late 1997, and converted it into the

company's main
                office. As the regulations on dioxin emissions were
tightened, the Tochigi
                prefectural government instructed the company to upgrade

an incineration
                facility in late 1998.

                However, before making the necessary improvements to the

facility, Nisso
                applied to the prefectural government to cease
operations at the facility in
                October 1999.




             Copyright 1999 The Yomiuri Shimbun




               / R.P. case bares inadequacy of waste rules




               Yomiuri Shimbun

               The illegal export of hazardous waste by a Japanese
company to the
               Philippines can only be termed a disgraceful
international environmental
               crime. About 2,700 tons of Japanese garbage in 122
containers was
               shipped back to Japan on Monday and unloaded Tuesday.

               The export of the garbage violates the Basel Convention
that regulates
               cross-border transportation of hazardous waste and its
disposal. Because,
               under the convention, an exporting country is responsible

for the collection
               of such waste, the Japanese government chartered a ship
for the return of
               the garbage from the Philippines.

               The "forced repatriation" of waste was a duty that brings

shame upon Japan
               as a member of the international community.

               Much of the garbage is infectious and toxic medical
waste. Nisso Ltd., an
               industrial waste-processing company in Tochigi
Prefecture, exported the
               items under the description "waste paper for recycling."

               The exposure was the first in Japan of large-scale
dumping of waste in
               contravention of international law, but it is doubtful
that this is just a one-off
               isolated incident. It is almost certain that there are
other cases in which waste
               is exported to developing countries with less restrictive

regulations under the
               guise of "resource exports" for recycling. The illegal
practice appears to be
               well established.

               Leave no stone unturned in investigation

               Investigative and administrative authorities have a duty
to expose the entire
               process, from start to finish, by which the returned
waste turned up in the
               Philippines, from the firms that produced it to the one
that processed it and
               the Philippine company that imported it. The system with
a flaw that allowed
               the waste to be illegally exported should be reexamined.

               The current controversy illustrates the seriousness of
the waste-disposal
               problem in Japan.

               The industrial waste-processing company in question had
earlier been found
               responsible for the illegal dumping of about 8,000 tons
of waste in Ibaraki
               Prefecture, Nagano Prefecture and elsewhere. The company
might have
               stepped up illegal dumping after being forced to shut
down incinerators that
               it failed to upgrade to meet tightened standards for
dioxin emissions that
               were introduced in late December of 1998.

               It seems that the latest case has revealed a vicious
circle in which tighter
               rules encouraged more illegal dumping, and, in turn, more

tightening of
               controls to follow. One of the offshoots was the illegal
exportation to the
               Philippines.

               Tackle the problem at its source

               To break the circle, we must clarify and expand the
responsibility of waste
               producers, thereby tackling the problem at its source.
This issue is
               addressed in a bill for the revision of the Wastes
Disposal Law due to be
               submitted during the next ordinary Diet session.

               But the current law already stipulates responsibility of
waste producers.
               They are required to record details of waste in a
manifesto, hand it to a
               waste-disposal company and confirm how disposal was made.

The reality of
               the situation is, however, that waste producers consider
their responsibility
               to be at an end at the second the waste is handed over to

the disposal firm.
               Rampant falsification of manifestos enables them to get
away with it, making
               the system of record-keeping null and void.

               The revision bill would make it mandatory for waste
producers to verify
               correct disposal in line with details recorded on
manifestos. The producer
               knows best about the content and composition of its waste

and should be
               made duty-bound to see its disposal through to the end.

               The revision bill also seeks to lay a level of
responsibility with waste
               producers for the recovery of waste found to have been
dumped illegally or
               improperly disposed of in other ways. This burden must be

distributed fairly.

               It costs several hundreds of millions of yen to dispose
of waste shipped back
               to Japan. The cost will be borne by the Environment
Agency, Health and
               Welfare and International Trade and Industry ministries
instead of the
               waste-disposal company.

               Despite the extent of the disgrace, we must seize the
opportunity presented
               by the latest illegal exportation case to formulate a new

waste-disposal
               policy.







From ntangri@essential.org Wed, 12 Jan 2000 13:25:27 -0500
Date: Wed, 12 Jan 2000 13:25:27 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] WB tries to build incinerator in Philippines

Hi folks,

As you probably have heard, there is now a legal ban on incineration in
place in the Philippines. In spite of this, the International Finance
Corporation, the private-sector lending arm of the World Bank, is
attempting to finance the construction of a medical waste incinerator as
part of a new high-end hospital near Manila. The documents are available at:

http://www.worldbank.org/pics/ifcers/phe09503.txt
http://www.worldbank.org/pics/ifcspi/phs09503.txt


Neil






From ntangri@essential.org Wed, 12 Jan 2000 13:26:41 -0500
Date: Wed, 12 Jan 2000 13:26:41 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] another dastardly World Bank project

Here's another project by the same arm of the World Bank, which would
greatly increase the quantity of medical waste sent to an existing
incinerator in Vietnam:

http://www.worldbank.org/pics/ifcers/vne08137.txt

If you're interested in any of these documents and can't download them,
I"ll be happy to email them to you as plain text.

Neil






From ARNOLD.SCHECTER@email.swmed.edu Wed, 12 Jan 2000 13:58:41 -0600
Date: Wed, 12 Jan 2000 13:58:41 -0600
From: Arnold Schecter ARNOLD.SCHECTER@email.swmed.edu
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in
 drinkingwater distribution

Dear Pat: Did you see the CNN transcript of their rebroadcast of CBS 60 =
Minute Agent Orange show with junkscience.com man getting last words ! ? =
-Broadcast to Asia and Europe. -Arnold






From pat.costner@dialb.greenpeace.org Wed, 12 Jan 2000 16:43:35 -0600
Date: Wed, 12 Jan 2000 16:43:35 -0600
From: pat.costner@dialb.greenpeace.org pat.costner@dialb.greenpeace.org
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine in	drinkingwater distribution

Hi, Arnold

Good to hear from you!  No, I missed that.  If you still have it and it's 
easy, please forward it.

Best regards,

Pat


On 12 Jan 00, at 13:58, Arnold Schecter wrote:
Re: [Dioxin-l] Re: Poor efficacy of residual chlo

> Dear Pat: Did you see the CNN transcript of their rebroadcast of CBS 60
> Minute Agent Orange show with junkscience.com man getting last words ! ?
> -Broadcast to Asia and Europe. -Arnold
> 


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
Greenpeace
P.O. Box 548
 or 512 County Road 2663
Eureka Springs, Arkansas 72632
ph: 1 501 253 8440
fx: 1 501 253 5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~





From ttweed@wildrockies.org Wed, 12 Jan 2000 16:45:39 -0700
Date: Wed, 12 Jan 2000 16:45:39 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] Supremes rule 7-2 for citizen standing to sue!!!

I've followed this and relted cases some, but of course I'm not intimate w/
the arguments--yet this seems a quite unexpected and a huge repudiation of
Scalia and other fed judges recent successes in taking away citizen suits!
Inter alia, now CHEER's ground-breaking pollution prevention consent decree
w/ Smurfit-Stone Container has a greater chance of being duplicated
elsewhere.
--

From: "Peter W. Martin" <martin@WWW.LAW.CORNELL.EDU>
To: <liibulletin@www3.LAW.CORNELL.EDU>
Subject: LIIBULLETIN, Wednesday January 12  (4 cases)
Date: Wed, 12 Jan 2000 10:36:07 -0500

---------------------------------------------------------------
                         AN E-BULLETIN
       LEGAL INFORMATION INSTITUTE -- CORNELL LAW SCHOOL
                    lii@lii.law.cornell.edu
---------------------------------------------------------------
The following decisions have just arrived via the LII's
direct Project HERMES feed from the Supreme Court.

These are not the decisions themselves nor excerpts from them,
but summaries (syllabi) prepared by the Court's Reporter of
Decisions.  Instructions for accessing the full text of any of
these decisions are provided at the end of this bulletin, as are
instructions for subscribing in the event that this bulletin
has been given you by a colleague and you'd like a
subscription of your own.

===============================================================
FRIENDS OF EARTH, INC. v. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC.
(98-822)
Web-accessible at:
    http://supct.law.cornell.edu/supct/html/98-822.ZS.html

Argued October 12, 1999  -- Decided January 12, 2000
Opinion author: Ginsburg

===============================================================

Defendant-respondent Laidlaw Environmental Services (TOC),
Inc., bought a facility in Roebuck, South Carolina, that
included a wastewater treatment plant. Shortly thereafter, the
South Carolina Department of Health and Environmental Control
(DHEC), acting under the Clean Water Act (Act), 33 U.S.C. sect.
1342(a)(1), granted Laidlaw a National Pollutant Discharge
Elimination System (NPDES) permit.  The permit authorized
Laidlaw to discharge treated water into the North Tyger River,
but limited, among other things, the discharge of pollutants
into the waterway.  Laidlaw began to discharge various
pollutants into the waterway; these discharges, particularly of
mercury, an extremely toxic pollutant, repeatedly exceeded the
limits set by the permit.
On April 10, 1992, plaintiff-petitioners Friends of
the Earth and Citizens Local Environmental Action Network, Inc.
(referred to collectively here, along with later joined
plaintiff-petitioner Sierra Club, as "FOE"), notified Laidlaw
of their intention to file a citizen suit against it under the
Act, 33 U.S.C. sect. 1365(a), after the expiration of the
requisite 60-day notice period.  DHEC acceded to Laidlaw's
request to file a lawsuit against the company. On the last day
before FOE's 60-day notice period expired, DHEC and Laidlaw
reached a settlement requiring Laidlaw to pay $100,000 in civil
penalties and to make "every effort" to comply with its permit
obligations.
On June 12, 1992, FOE filed this citizen suit against
Laidlaw, alleging noncompliance with the NPDES permit and
seeking declaratory and injunctive relief and an award of civil
penalties.  Laidlaw moved for summary judgment on the ground
that FOE lacked Article III standing to bring the lawsuit.
After examining affidavits and deposition testimony from
members of the plaintiff organizations, the District Court
denied the motion, finding that the plaintiffs had standing.
The District Court also denied Laidlaw's motion to dismiss on
the ground that the citizen suit was barred under
sect.1365(b)(1)(B) by DHEC's prior action against the company.
After FOE initiated this suit, but before the District Court
rendered judgment on January 22, 1997, Laidlaw violated the
mercury discharge limitation in its permit 13 times and
committed 13 monitoring and 10 reporting violations.  In
issuing its judgment, the District Court found that Laidlaw had
gained a total economic benefit of $1,092,581 as a result of
its extended period of noncompliance with the permit's mercury
discharge limit; nevertheless, the court concluded that a civil
penalty of $405,800 was appropriate.  In particular, the
District Court found that the judgment's "total deterrent
effect" would be adequate to forestall future violations, given
that Laidlaw would have to reimburse the plaintiffs for a
significant amount of legal fees and had itself incurred
significant legal expenses.  The court declined to order
injunctive relief because Laidlaw, after the lawsuit began, had
achieved substantial compliance with the terms of its permit.
FOE appealed as to the amount of the District Court's
civil penalty judgment, but did not appeal the denial of
declaratory or injunctive relief.  The Fourth Circuit vacated
the District Court's order and remanded with instructions to
dismiss the action.  Assuming, arguendo, that FOE initially had
standing, the appellate court held that the case had become
moot once Laidlaw complied with the terms of its permit and the
plaintiffs failed to appeal the denial of equitable relief.
Citing Steel Co. v. Citizens for Better Environment, 523 U.S.
83, the court reasoned that the only remedy currently available
to FOE, civil penalties payable to the Government, would not
redress any injury FOE had suffered. The court added that FOE's
failure to obtain relief on the merits precluded recovery of
attorneys' fees or costs because such an award is available
only to a "prevailing or substantially prevailing party" under
sect.1365(d).  According to Laidlaw, the entire Roebuck
facility has since been permanently closed, dismantled, and put
up for sale, and all discharges from the facility have
permanently ceased.

Held:  The Fourth Circuit erred in concluding that a citizen
suitor's claim for civil penalties must be dismissed as moot
when the defendant, after commencement of the litigation, has
come into compliance with its NPDES permit.  Pp. 8-25.
    (a)  The Constitution's case-or-controversy limitation on
federal judicial authority, Art. III, sect.2, underpins both
standing and mootness doctrine, but the two inquiries differ in
crucial respects.  Because the Fourth Circuit was persuaded
that the case had become moot, it simply assumed that FOE had
initial standing.  See Arizonans for Official English v.
Arizona, 520 U.S. 43, 66-67.  But because this Court concludes
that the Court of Appeals erred as to mootness, this Court has
an obligation to assure itself that FOE had Article III
standing at the outset of the litigation.  Pp. 8-9.
    (b)  FOE had Article III standing to bring this action.
This Court has held that to satisfy Article III's standing
requirements, a plaintiff must show "injury in fact,"
causation, and redressability. Lujan v. Defenders of Wildlife,
504 U.S. 555, 560-561. An association has standing to bring
suit on behalf of its members when its members would have
standing to sue in their own right, the interests at stake are
germane to the organization's purpose, and neither the claim
asserted nor the relief requested requires individual members'
participation in the lawsuit.  Hunt v. Washington State Apple
Advertising Comm'n, 432 U.S. 333, 343. The relevant showing
for Article III standing is not injury to the environment but
injury to the plaintiff.  To insist on the former rather than
the latter is to raise the standing hurdle higher than the
necessary showing for success on the merits in a citizen's
NPDES permit enforcement suit. Here, injury in fact was
adequately documented by the affidavits and testimony of FOE
members asserting that Laidlaw's pollutant discharges, and the
affiants' reasonable concerns about the effects of those
discharges, directly affected those affiants' recreational,
aesthetic, and economic interests.  See, e.g., Sierra Club v.
Morton, 405 U.S. 727, 735. These submissions present
dispositively more than the mere "general averments" and
"conclusory allegations" found inadequate in Lujan v. National
Wildlife Federation, 497 U.S. 871, 888, or the " 'some day'
intentions" to visit endangered species halfway around the
world held insufficient in Defenders of Wildlife.  504 U.S., at
564.  Pp. 9-13.
    (c)  Laidlaw argues that FOE lacked standing to seek
civil penalties payable to the Government, because such
penalties offer no redress to citizen plaintiffs.  For a
plaintiff who is injured or threatened with injury due to
illegal conduct ongoing at the time of suit, a sanction that
effectively abates that conduct and prevents its recurrence
provides a form of redress.  Civil penalties can fit that
description.  Insofar as they encourage defendants to
discontinue current violations and deter future ones, they
afford redress to citizen plaintiffs injured or threatened with
injury as a result of ongoing unlawful conduct.  The Court need
not explore the outer limits of the principle that civil
penalties provide sufficient deterrence to support
redressability, because the civil penalties sought here carried
a deterrent effect that made it likely, as opposed to merely
speculative, that the penalties would redress FOE's
injuries--as the District Court reasonably found when it
assessed a penalty of $405,800.  Steel Co. is not to the
contrary.  That case held that private plaintiffs may not sue
to assess penalties for wholly past violations, 523 U.S., at
106-107, but did not address standing to seek penalties for
violations ongoing at the time of the complaint that could
continue into the future if undeterred, see id., at 108.  Pp.
13-17.
    (d)  FOE's civil penalties claim did not automatically
become moot once the company came into substantial compliance
with its permit.  A defendant's voluntary cessation of a
challenged practice ordinarily does not deprive a federal court
of its power to determine the legality of the practice. City of
Mesquite v. Aladdin's Castle, Inc., 455 U.S. 283, 289. If it
did, courts would be compelled to leave the defendant free to
return to its old ways.  Thus, the standard for determining
whether a case has been mooted by the defendant's voluntary
conduct is stringent: A case might become moot if subsequent
events make it absolutely clear that the allegedly wrongful
behavior could not reasonably be expected to recur.  United
States v. Concentrated Phosphate Export Assn., Inc., 393 U.S.
199, 203.  The heavy burden of persuading the court that the
challenged conduct cannot reasonably be expected to recur lies
with the party asserting mootness.  Ibid.  The Court of Appeals
incorrectly conflated this Court's case law on initial
standing, see, e.g., Steel Co., with its case law on mootness,
see, e.g., City of Mesquite.  Such confusion is understandable,
given this Court's repeated description of mootness as "the
doctrine of standing set in a time frame: The requisite
personal interest that must exist at the commencement of the
litigation (standing) must continue throughout its existence
(mootness)."  E.g., Arizonans, 520 U.S., at 68, n. 22. Careful
reflection, however, reveals that this description of mootness
is not comprehensive.  For example, a defendant claiming that
its voluntary compliance moots a case bears a formidable
burden.  By contrast, it is the plaintiff's burden, in a
lawsuit brought to force compliance, to establish standing by
demonstrating that, if unchecked by the litigation, the
defendant's allegedly wrongful behavior will likely occur or
continue and that the threatened injury is certainly impending.
Whitmore v. Arkansas, 495 U.S. 149, 158.  The plain lesson is
that there are circumstances in which the prospect that a
defendant will engage in (or resume) harmful conduct may be too
speculative to support standing, but not too speculative to
overcome mootness.  Further, if mootness were simply "standing
set in a time frame," the exception to mootness for acts that
are "capable of repetition, yet evading review" could not
exist. See, e.g., Olmstead v. L. C., 527 U.S. ___, ___, n. 6.
Standing admits of no similar exception; if a plaintiff lacks
standing at the time the action commences, the fact that the
dispute is capable of repetition yet evading review will not
entitle the complainant to a federal judicial forum.  See,
e.g., Steel Co., 523 U.S., at 109.  Standing doctrine ensures,
among other things, that the resources of the federal courts
are devoted to disputes in which the parties have a concrete
stake. Yet by the time mootness is an issue, abandonment of
the case may prove more wasteful than frugal.  Courts have no
license to retain jurisdiction over cases in which one or both
of the parties plainly lacks a continuing interest, see, e.g.,
Arizonans, 520 U.S., at 67, but the foregoing examples
highlight an important difference between the two doctrines,
see generally Honig v. Doe, 484 U.S. 305, 329-332 (Rehnquist,
C. J., concurring).
Laidlaw's argument that FOE doomed its own civil penalty
claim to mootness by failing to appeal the denial of injunctive
relief misconceives the statutory scheme.  Under sect.1365(a),
the district court has discretion to determine which form of
relief is best suited to abate current violations and deter
future ones.  See Weinberger v. Romero&nbhyph;Barcelo, 456 U.S.
305, 313.  Denial of injunctive relief does not necessarily
mean that the district court has concluded there is no prospect
of future violations to deter. Indeed, it meant no such thing
in this case; the District Court denied injunctive relief, but
expressly based its award of civil penalties on the need for
deterrence.  A district court properly may conclude that an
injunction would be too intrusive, because it could entail
continuing and burdensome superintendence of the permit
holder's activities by a federal court.  See City of Mesquite,
455 U.S., at 289.  Both Laidlaw's permit compliance and the
facility closure might moot this case, but only if one or the
other event made it absolutely clear that violations could not
reasonably be expected to recur.  Concentrated Phosphate Export
Assn., 393 U.S., at 203.  These are disputed factual matters
that have not been aired in the lower courts; they remain open
for consideration on remand.  Pp. 18-23.
    (e)  This Court does not resolve FOE's argument that it
is entitled to attorneys' fees on the theory that a plaintiff
can be a "prevailing party" under sect.1365(d) if it was the
"catalyst" that triggered a favorable outcome. Although the
Circuits have divided as to the continuing validity of the
catalyst theory following Farrar v. Hobby, 506 U.S. 103, it
would be premature for this Court to address the question here.
The District Court stayed the time for a petition for
attorneys' fees until the time for appeal had expired or until
any appeal was resolved.  Thus, when the Fourth Circuit
addressed the availability of counsel fees, no order was before
it either denying or awarding fees.  It is for the District
Court, not this Court, to address in the first instance any
request for reimbursement of costs, including fees.  Pp. 23-25.

149 F.3d 303, reversed and remanded.

Ginsburg, J., delivered the opinion of the Court, in which
Rehnquist, C. J., and Stevens, O'Connor, Kennedy, Souter, and
Breyer, JJ., joined.  Stevens, J., and Kennedy, J., filed
concurring opinions.  Scalia, J., filed a dissenting opinion,
in which Thomas,  J., joined.

===============================================================







From ntangri@essential.org Thu, 13 Jan 2000 14:38:06 -0500
Date: Thu, 13 Jan 2000 14:38:06 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] Right To Sue Polluters Upheld

http://www.nytimes.com/aponline/w/AP-Scotus-Clean-Water.html
January 12, 2000

          Right To Sue Polluters Upheld

          Filed at 6:36 p.m. EST

          By The Associated Press

          WASHINGTON (AP) -- Private citizens won assurances from the
          Supreme Court on Wednesday that they can seek enforcement of
          environmental laws against polluters. 

          The justices, in a 7-2 decision, upheld citizen groups' right to
sue an
          alleged polluter even if the group were not directly harmed by the
          pollution or could prove financial damages. 

          The ruling also said polluters sued by private citizens cannot
necessarily
          avoid paying damages by stopping their misconduct during
litigation. 

          The decision involved the dumping of toxic chemicals into a
stream from
          a South Carolina hazardous waste incinerator. Friends of the
Earth and
          several other environmental groups sued incinerator's operator in
1992,
          although these groups were not directly harmed by the pollution. 

          The ruling ``assures that citizens ... have the right to go to
court to
          enforce environmental laws,'' said Lois Schiffer, assistant
attorney general
          for environment and natural resources, applauding the court's
finding. 

          The case against Laidlaw Environmental Services, operator of the
          incinerator, was a test of the Clean Water Act's provision that
allows
          private citizens to file lawsuits to help enforce the law. Under
the law,
          citizens can seek an end to misconduct, plus financial penalties
to be paid
          to the federal government. 

          ``This case had the potential to severely limit a citizen's
ability to enforce
          the Clean Water Act.,'' said Brian Dunkiel of Friends of the
Earth. ``We
          ... are pleased that the court has maintained the status quo'' on
citizen
          participation. 

          The suit dealt with Laidlaw's operation of its waste incinerator in
          Roebuck, S.C., that discharged wastewater into the North Tyger
River. 

          By the time a federal judge ruled on the lawsuit in 1997, Laidlaw
had
          come into compliance of the Clean Water Act. While the judge found
          that the environmental groups were not entitled to an order to
deter future
          violations, he imposed $405,800 in civil penalties for past
violations. 

          A year later, the 4th U.S. Circuit Court of Appeals threw out the
penalty.
          It said that once the judge decided not to ban future violations,
the only
          remaining remedy -- a civil penalty -- was not appropriate
because it
          would not benefit the groups who filed suit. Under the law, the
money
          had to be paid to the government. 

          But the Supreme Court said the civil penalty was intended to
deter future
          misconduct, and therefore it would, in fact, benefit the
environmental
          groups. 

          The justices ordered the case returned to a lower court to determine
          whether Laidlaw could show that the case was moot because future
          violations could not be expected to occur. 

          ``Congress has found that civil penalties in the Clean Water Act
cases do
          more than promote immediate compliance ... they also deter future
          violations,'' Justice Ruth Bader Ginsburg wrote for the court. 

          ``A defendant's voluntary cessation of allegedly unlawful conduct
          ordinarily does not suffice to moot a case,'' Ginsburg added. A case
          might be declared moot if it were clear that the unlawful conduct
could
          not reasonably be expected to reoccur, she said. 

          Ginsburg's opinion was joined by Chief Justice William H.
Rehnquist and
          Justices John Paul Stevens, Sandra Day O'Connor, Anthony M.
          Kennedy, David H. Souter and Stephen G. Breyer. 

          Justices Antonin Scalia and Clarence Thomas dissented. Writing
for the
          two, Scalia said the ruling permited ``law enforcement to be
placed in the
          hands of private individuals.'' 

          The case is Friends of the Earth vs. Laidlaw Environmental Services,
          98-822. 





From ntangri@essential.org Thu, 13 Jan 2000 14:40:34 -0500
Date: Thu, 13 Jan 2000 14:40:34 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] Gore's '92 Promise on Incinerator Propels Ohio Demonstrators
 in '00

http://www.nytimes.com/library/politics/camp/011300wh-dem-gore-promise.html

January 13, 2000

          THE ELECTORATE

          Gore's '92 Promise on Incinerator Propels
          Ohio Demonstrators in '00

          By FRANCIS X. CLINES

               EAST LIVERPOOL, Ohio, Jan. 10 -- An old press release from
               Vice President-elect Al Gore, issued in the first flush of
victory in
          1992, is being preserved here like the Magna Carta. 

          And seven years after he issued that release pledging to block
the local
          hazardous-waste incinerator that has become a national environmental
          cause, the same determined protesters who believed Mr. Gore in 1992
          and have dogged him ever since -- staging protests and suffering
arrests
          -- are on his trail once more as he heads for Ohio's presidential
primary
          on March 7. 

                                "Maybe he's developed a bit of courage,"
                                said Terri Swearingen, a registered nurse
                                and barbed opponent of the toxic chemical
                                waste incinerator, which vents steadily into
                                the air, day after day, just 1,100 feet from
                                an elementary school attended by 400
                                children in this humble Ohio River Valley
                                town. 

                                "This is Gore's broken promise," said Ms.
          Swearingen, a who has been arrested nine times and who was
carried off
          from one sit-in inside the White House two months into the
Clinton-Gore
          administration, after she found the waste incinerator going into
operation
          despite campaign pledges. 

          "You promised!" she and her colleagues have shouted at the Vice
          President across Mr. Gore's seven years in office even as the
          administration insisted it discovered that it was legally unable
to block the
          plant's opening because in the final weeks of the Bush
administration
          approval was granted to test the plant's furnace. 

          "Read your book!" critics have shouted, reminding Mr. Gore, the
          environmentalist author, of his assertion that he is the
nonpareil political
          watchdog on the issue. 

          In response to questions, Mr. Gore's office said this week that "as
          promised, we looked exhaustively" at the issue and found the
initial test
          permit from the Bush administration "can't be revoked unless we can
          prove it violated health and safety standards." At least two
reviews could
          find no violations, said Melissa Bonney Ratcliff, a spokeswoman
for the
          vice president. 

          A month after the Clinton-Gore victory in 1992, Mr. Gore, a leading
          critic of incineration, promised that the new administration
would prevent
          the plant from opening until Congress investigated its safety and
how it
          had got federal approval. 

          "The very idea of putting it in a flood plain, you know, it's just
          unbelievable to me," candidate Gore had said of the incinerator
when he
          campaigned in July 1992 in nearby Weirton, W. Va. 

          "We'll be on your side for a change," he promised opponents. 

          In the third month of the new administration, the plant, operated by
          Waste Technologies Industries, was permitted to begin commercial
          operation. While Mr. Gore has maintained the incinerator could
not be
          blocked, environmentalists insist it could have been stopped if the
          Clinton-Gore team had resolved to do so after the election. 

          Ms. Swearingen and other opponents have been fighting the regional
          commercial incinerator, from proposal to construction, across the
past 20
          years, turning a mayor out of office here over the issue. In now
pointing
          to the Ohio primary, they are determined to show that a candidate's
          pledge that goes around, comes around. 

          "We are reminding Mr. Gore of his promise as he runs on his own,"
said
          Alonzo Spencer, a retired steel worker who is galvanizing his
Save Our
          County protest group once more at this fresh opportunity to
single out the
          incinerator. 

          In advance of the primary, a dozen organizations, including the
          environmental group Greenpeace and Ms. Swearingen's Tri-State
          Environmental Council, have requested a meeting about the
incinerator
          with Vice President Gore, promising there will be no new
          civil-disobedience disruptions, at least not "at or during this
meeting." 

          "We are now feeling that the health effects we first warned about
back
          then are starting to come true," Mr. Spencer said, referring to a
state
          health study in 1997 that reported "strikingly higher" cancer
mortality
          rates for East Liverpool than for the state and nation. 

          The local cancer mortality rate for the four years through 1995 was
          235.0 per 100,000, compared with 182.6 for the state and 172.2
for the
          nation. Mr. Spencer agrees the causes of cancer can be complex and
          long running, but he insists that opening the plant so close to a
school in a
          troubled region of old steel, foundry and pottery industries
"exacerbated
          an already high-risk situation." A detailed study has been
started to
          search for causal evidence beyond the data, with no definitive
tie yet
          reported to the incinerator. 

          The plant annually burns 63,000 tons of hazardous waste,
including lead,
          mercury and hundreds of other toxic chemicals. Gases and
particles from
          the smokestack, including dioxin, are supposed to be within
permissible
          federal limits, but opponents note that the state fined the plant
$126,000
          for violations of air monitoring requirements. 

          The plant's proximity to East Elementary School has been
underlined in
          various studies as a potentially risky situation. A state law
adopted soon
          after the incinerator began operating required at least 2,000
feet of
          separation between schools or homes and any new incinerators, almost
          double the safety margin here. 

          As the primary approaches, critics are emphasizing that the
incinerator
          has been operating on an interim basis ever since the initial
federal permit
          expired in 1995. So this is the time to press Mr. Gore over the
issue
          once more and try to embarrass him if necessary, according to the
          opposition, whose prowess is well tested. 

          "I've already talked about this with Bill Bradley," the tireless Ms.
          Swearingen said of the former New Jersey senator who is
challenging the
          vice president in the primary. "We are always looking for that
one person
          to take this seriously." 

          Rick Hind, legislative director for Greenpeace's campaign against
toxic
          wastes, speculated that Mr. Gore was "assuming the environmental
vote
          is in his pocket." 

          "We went from great hope to great disappointment," Mr. Hind said
of the
          Clinton-Gore team's handling of the East Liverpool issue, in
which, he
          said, they moved from opposition as candidates to their
administration's
          joining the company in defense of the plant in a subsequent
lawsuit. 

          Steady as the plume pouring from the incinerator stack, the
politics of the
          March 7 primary are being pursued by small-town environmentalists
with
          a memory for pledges past. 

          "This was their very first environmental promise," Ms. Swearingen
said,
          protecting that 1992 press release. "And it was their first promise
          broken." 





From ntangri@essential.org Fri, 14 Jan 2000 11:12:05 -0500
Date: Fri, 14 Jan 2000 11:12:05 -0500
From: Neil Tangri ntangri@essential.org
Subject: [Dioxin-l] TOKYO TO NEUTRALIZE BURNT ASH TO COMBAT DIOXIN

When Paul Connett & I were in Japan, we saw one incinerator that included a
completely-enclosed furnace for the vitrification of fly ash. They used oil
to heat the ash hot enough to melt the ash into a glass-like substance,
which should make it less likely to contaminate groundwater supplies, etc.
I also understand that these temperatures are sufficient to break down the
dioxin; but I don't know what keeps it from re-forming in the exhaust.

In any case, this is an extremely expensive and energy-intensive operation.
The engineers at the plant told us that the vitrification furnace alone
consumed more energy than the entire waste-to-energy plant produced.

Neil



THURSDAY, JANUARY 13, 2000, EVENING EDITION

SANKEI (SOCIETY PAGE)                  000113E

 TOKYO TO NEUTRALIZE BURNT ASH TO COMBAT DIOXIN
 TOKYO =96 The Tokyo metropolitan government decided by January 13 to
treat
burnt ash with high temperatures to reduce dioxin that is generated in
the
process of disposing of garbage.  The government is planning to apply
this
measure to all burnt ash generated in the 23 wards by 2006.  The measure

will be the first to be adopted by prefectural governments.
 Tokyo=92s flammable waste amounts to three million tons a year.  Ash from
the
incinerators is dumped in the shielded landfill in the Bay of Tokyo so
that
dioxin won=92t escape into the soil.  However, 80% of dioxin generated
while
disposing of waste still comes from the ash.  To trim down the dioxin
generation, Tokyo officials decided to build plants which can make slug
from
the ash by treating it with a temperature of 1,200 degrees or higher.
Incineration can reduce the volume of waste of three million tons to ash
of
300,000 tons.  The new plants can further cut down the volume of ash by
half
as dioxin becomes harmless compounds.  A total cost for the plants is
about
64 billion yen.








From pat.costner@dialb.greenpeace.org Fri, 14 Jan 2000 12:12:53 -0600
Date: Fri, 14 Jan 2000 12:12:53 -0600
From: pat.costner@dialb.greenpeace.org pat.costner@dialb.greenpeace.org
Subject: [Dioxin-l] Impacts of chlorine-bleaching pulp & paper mills

Joy, 

Perhaps this study is of interest to you as well as others who are in 
the vicinity of chlorine-bleaching pulp and paper mills.  One of the 
more interesting aspects of this study is bioaccumulation of 
chemicals that are of a size regarded by some to be too large to 
bioaccumulate. 

Pat


M. Salkinoja-Salonen, Jussi Uotila, J. Jokela, M. Laine, and E. 
Saski.  Organic Halogens in the Environment: Studies of 
Environmental Biodegradability and Human Exposure. Environ 
Health Perspect 103(Suppl 6):00-00 (1995)

Abstract

Organic halogens from chlorobleaching of kraft pulp were not as 
biorecalcitrant as has been assumed. Fifty percent were
removed during biotreatment of wastewater, and 50% of the 
remaining organohalogens faded in fresh water ecosystems in 200
to 400 days. Molecular size seemed not to hinder biodegradation 
up to sizes of approximately 2000 daltons. Anoxic
biodegradation was of prime importance for halomineralization of 
pulp bleaching organohalogens but could also lead to toxic
metabolites such as vinyl chloride from tri- and tetrachloroethene in 
anoxic soil. Indigenous soil microbes were unable to clean
old organohalogen pollution but had converted chlorophenols into 
polymeric substances, chlorohumus which were found
bioaccumulable by earthworms in spite of the large (up to 5000 
g/mole) molecular sizes. Because of the danger of formation of
toxic metabolites, the biochemistry of the xenobiotic degradation 
must be elucidated before active bioremediation is practiced
on polluted soil or water. Groundwater pollution by chlorophenols 
led to increased disease among the exposed population in
one well-studied case. Two further cases of potential environmental 
health impact are described. 
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
Greenpeace
P.O. Box 548
 or 512 County Road 2663
Eureka Springs, Arkansas 72632
ph: 1 501 253 8440
fx: 1 501 253 5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~





From bphata@sedona.net Fri, 14 Jan 2000 11:32:25 -0700
Date: Fri, 14 Jan 2000 11:32:25 -0700
From: Bill Patterson bphata@sedona.net
Subject: [Dioxin-l] Re: Poor efficacy of residual chlorine
 indrinkingwater distribution

At 01:58 PM 1/12/00 -0600, Arnold Schecter wrote:

>Dear Pat: Did you see the CNN transcript of their rebroadcast of CBS 60 Minute >Agent Orange show with junkscience.com man getting last words ! ? -Broadcast to >Asia and Europe. -Arnold


Do any of you know how to get a copy of the above.

Thanks in advance,

Bill Patterson

Sedona, Arizona

<<><<



<center><bold>http://www.kachina.net/~bphata/medprobs.htm</bold>





From MPU_Labor@t-online.de Fri, 14 Jan 2000 20:58:50 +0100
Date: Fri, 14 Jan 2000 20:58:50 +0100
From: mpu_labor MPU_Labor@t-online.de
Subject: [Dioxin-l] EU and food safety

Hello,

the European Commission published on January 12, 2000 a more than 50 pages strong 
white paper on food safety. Main points in this paper are the establishment of an 
independent European Food Authority until 2002 and the improofment of the food 
safety standards in all EU countries. It is the consequence in particular of the 
Belgian dioxin scandal in 1999.

A copy of the white paper is available at:

http://www.dioxins.de/english.htm
or
http://www.dioxine.de/deutsch.htm

L.Müller
labor@mpu-gmbh.de






From ttweed@wildrockies.org Fri, 14 Jan 2000 21:57:59 -0700
Date: Fri, 14 Jan 2000 21:57:59 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] EPA agrees to ITC's voluntary data for APE's

"II. What is the Purpose of Today's Action?
...Specifically at the request of the ITC in a letter to EPA
dated September 15, 1997, EPA is not issuing a final TSCA section 8(d)
``Unpublished Health and Safety Data'' reporting rule at this time for
the 23 nonylphenol ethoxylates recommended for testing in the 39th ITC
Report so as to give the ITC an opportunity to implement the voluntary
information submission policy that was proposed in the ITC's 40th
Report (62 FR 30580, June 4, 1997) (FRL-5718-3).
...
     EPA reserves the right to issue a TSCA section 8(d) rule for some
or all of these 23 nonylphenol ethoxylates if:
   ...2. The ITC notifies EPA in writing that the ITC did not receive
adequate information via its voluntary information submission activity.
(The ITC's voluntary submission policy can be found on the ITC's[SNIP]"
---


[Federal Register: January 11, 2000 (Volume 65, Number 7)]
[Rules and Regulations]
[Page 1548-1554]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr11ja00-10]

-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Parts 712 and 716

[
OPPTS-82050; FRL-5777-2]
RIN-2070-AB08 and 2070-AB11


Preliminary Assessment Information and Health and Safety Data
Reporting; Addition and Removal of Certain Chemicals and Removal of
Stay

AGENCY: Environmental Protection Agency (EPA).

ACTION: Final rule.

-----------------------------------------------------------------------

SUMMARY: This final rule addresses the recommendations of the 39th TSCA
Interagency Testing Committee (ITC) Report by adding 19 of 23
recommended nonylphenol ethoxylates to the Toxic Substances Control Act
(TSCA) section 8(a) Preliminary Assessment Information Reporting (PAIR)
rule. The TSCA ITC in its 39th Report to EPA revised the TSCA section
4(e) Priority Testing List by recommending testing for 23 nonylphenol
ethoxylates, 19 of which are associated with unique Chemical Abstract
Service (CAS) Registry numbers. The ITC recommendations are given
priority consideration by EPA in promulgating TSCA section 4 test
rules. This PAIR rule will require manufacturers (including importers)
of the 19 CAS-numbered substances identified in this document to report
certain production, use, and exposure-related information to EPA. This
action also removes a stay for TSCA section 8(a) PAIR and section 8(d)
Health and Safety Data Reporting rules issued previously for 18
nonylphenol ethoxylates recommended by the TSCA ITC in its 38th Report
to EPA and removes those 18 chemicals from these reporting rules.

DATES: This rule is effective on February 10, 2000.

FOR FURTHER INFORMATION CONTACT: For general information contact:
Joseph S. Carra, Deputy Director, Office of Pollution Prevention and
Toxics (7401), Environmental Protection Agency, 401 M St., SW.,
Washington, DC 20460; telephone numbers: (202) 554-1404 and TDD: (202)
554-0551; e-mail address: TSCA-Hotline@epa.gov.
    For technical information contact: David R. Williams, Chemical
Control Division (7405), Office of Pollution Prevention and Toxics,
Environmental Protection Agency, 401 M St., SW., Washington, DC 20460;
telephone numbers: (202) 260-8130; e-mail address: ccd.citb@epa.gov.

SUPPLEMENTARY INFORMATION:

[[Page 1549]]

I. General Information:

A. Does This Action Apply to Me?

    You may be affected by this action if you manufacture (defined by
statute to include import) any of the chemical substances that are
listed in section 712.30(e) of the regulatory text portion of this
document. Entities potentially affected by this action may include, but
are not limited to:

--------------------------------------------------------------------------------
--------------------------------

Examples of Potentially
            Type of Entity                       SIC
NAICS              Affected Entities
--------------------------------------------------------------------------------
--------------------------------
Chemical manufacturers (including      28, 2911                 325, 32411
Persons who manufacture
 importers)
(defined by statute to

include import) one or

more of the subject

chemical substances.
--------------------------------------------------------------------------------
--------------------------------

    This listing is not intended to be exhaustive, but rather provides
a guide for readers regarding entities likely to be affected by this
action. The Standard Industrial Classification (SIC) codes and the
North American Industrial Classification System (NAICS) codes have been
provided to assist you and others in determining whether or not this
action might apply to certain entities. If you have any questions
regarding the applicability of this action to a particular entity,
consult the technical person listed in the ``FOR FURTHER INFORMATION
CONTACT'' section.

B. How Can I Get Additional Information or Copies of This Document or
Other Documents?

    1. Electronically. You may obtain electronic copies of this
document and other documents from the EPA Internet EPA Home Page at
http://www.epa.gov/. On the Home Page select ``Law and Regulations''
and then look up the entry for this document under ``Federal Register--
Environmental Documents.'' You can also go directly to the Federal
Register listings at http://www.epa.gov/fedrgstr/.
    2. In person. The official record for this proposed rule, which
includes the public version, has been established under docket control
number OPPTS-82050. The official record consists of the documents
referenced in this preamble, as well as any public comments, and other
information related to this rulemaking, including information claimed
as Confidential Business Information (CBI). This official record
includes the documents that are physically located in the docket, as
well as all documents that are referenced in those documents. The
public version of the official record does not include any information
claimed as CBI. The public version of the official record, which
includes printed, paper versions of any electronic comments that may be
submitted as described in Units I.C. and D. of this preamble, is
available for inspection in the TSCA Nonconfidential Information
Center, Rm. NE-B607, 401 M St., SW., Washington, DC. The Center is open
from noon to 4 p.m., Monday through Friday, excluding legal holidays.
The telephone number of the Center is (202) 260-7099.

C. How and to Whom Do I Submit Comments?

     You may submit comments through the mail, in person, or
electronically. To ensure proper receipt by EPA, your comments must
identify docket control number OPPTS-82050 in the subject line on the
first page of your response.
    1. By mail. Submit comments to: Document Control Office (7407),
Office of Pollution Prevention and Toxics, Environmental Protection
Agency, 401 M St., SW., East Tower, Rm. G-099, Washington, DC 20460.
    2. In person or by courier. Deliver comments to: Document Control
Office, Office of Pollution Prevention and Toxics, Environmental
Protection Agency, 401 M St., SW., East Tower, Rm. G-099, Washington,
DC. The telephone number for the OPPT Document Control Office is (202)
260-7093.
    3. Electronically. Submit your comments electronically by e-mail
to: oppt.ncic@epa.gov, or you may mail or deliver your computer disk to
the addresses identified in Units I.C.1. or 2. of this preamble. Do not
submit any information electronically that you consider to be CBI.
Submit comments as an ASCII file, avoiding the use of special
characters and any form of encryption. Comments will also be accepted
on standard disks in WordPerfect 6.1/8.0 or ASCII file format. All
copies of electronic comments must be identified by docket control
number OPPTS-82050. Electronic comments may be filed online at many
Federal Depository Libraries.

D. How Should I Handle CBI Information That I Want To Submit To The
Agency?

    Do not submit any information electronically that you consider to
be CBI. You may claim information that you submit in response to this
document as CBI by marking any part or all of that information as CBI.
Information so marked will not be disclosed except in accordance with
procedures set forth in 40 CFR part 2. In addition to one complete
version of the comments that include any information claimed as CBI, a
copy of the comments that does not contain the information claimed as
CBI must be submitted for inclusion in the public version of the
official record. Information not marked confidential will be included
in the public version of the official record by EPA without prior
notice. If you have any questions about CBI or the procedures for
claiming CBI, consult the technical person identified in ``FOR FURTHER
INFORMATION CONTACT''at the beginning of this preamble.

II. What is the Purpose of Today's Action?

    In today's action, EPA is issuing a final TSCA section 8(a)
``Preliminary Assessment Information Reporting'' (PAIR) rule for 19 of
23 nonylphenol ethoxylates recommended for testing in the 39th TSCA ITC
Report to the EPA Administrator (62 FR 8578, February 25, 1997) (FRL-
5580-9). Specifically at the request of the ITC in a letter to EPA
dated September 15, 1997, EPA is not issuing a final TSCA section 8(d)
``Unpublished Health and Safety Data'' reporting rule at this time for
the 23 nonylphenol ethoxylates recommended for testing in the 39th ITC
Report so as to give the ITC an opportunity to implement the voluntary
information submission policy that was proposed in the ITC's 40th
Report (62 FR 30580, June 4, 1997) (FRL-5718-3). Also in today's
action, EPA is removing the ``stay'' (61 FR 65186, December 11, 1996)
(FRL-5577-6) that was issued for the TSCA section 8(a) and TSCA section
8(d) rules (61 FR 55871, October 29, 1996) (FRL-5397-9) promulgated by
the Agency for the 18 nonylphenol ethoxylates recommended for testing
in

[[Page 1550]]

the ITC's 38th Report (61 FR 39832, July 30, 1996) (FRL-5379-2).
Further, EPA is revoking those TSCA section 8(a) and TSCA section 8(d)
rules issued on October 29, 1996.

III. What is the Basis for Today's Action?

     On May 31, 1996, EPA received the 38th Report of the TSCA Section
4 ITC. In the 38th Report, the ITC recommended 18 nonylphenol
ethoxylates for testing under section 4 of TSCA (61 FR 39832, July 30,
1996). In response to the ITC's 38th Report, EPA promulgated final TSCA
section 8(a) ``Preliminary Assessment Information Reporting'' (PAIR)
and TSCA section 8(d) ``Unpublished Health and Safety Data'' reporting
rules (61 FR 55871, October 29, 1996) (FRL-5397-9) for the 18
nonylphenol ethoxylates listed in the ITC's 38th Report.
     Shortly after the effective date for these TSCA rules, EPA became
aware of the fact that the ITC's use of some alternate CAS numbers and
several unclear chemical names in the 38th Report had resulted in
confusion among U.S. producers, importers, and processors about the
exact identities of the chemical substances for which TSCA section 8(a)
and 8(d) reporting was being required. In order to eliminate further
confusion within the regulated community about the actual identities of
the subject chemicals, EPA formally ``stayed'' the TSCA section 8(a)
and 8(d) rules for the 18 nonylphenol ethoxylates recommended in the
ITC's 38th Report. EPA issued this stay on December 11, 1996 (61 FR
65186) and also requested the ITC to clarify the identities of the
nonylphenol ethoxylates recommended in its 38th Report.
    In an attempt to eliminate the ambiguities resulting from the ITC's
use of alternate CAS numbers and unclear chemical names for the 18
nonylphenol ethoxylates recommended in its 38th Report, the ITC, in its
39th Report to the EPA Administrator, recommended for testing a revised
list comprised of 23 nonylphenol ethoxylates (62 FR 8578, February 25,
1997). According to the 39th Report, the ITC had re-examined its use of
alternate CAS numbers for several of the 18 nonylphenol ethoxylates
recommended in the 38th Report and determined that 5 of those CAS
numbers were not associated with any of the 18 chemical substances.
     For the 23 nonylphenol ethoxylates recommended in the 39th Report,
the ITC provided where possible more accurate CAS numbers and more up-
to-date chemical names (using 9th Collective Index chemical
nomenclature where possible). In a letter addressed to the EPA
Administrator dated September 15, 1997, the ITC formally requested that
EPA:
    1. Revoke the TSCA section 8(a) PAIR and TSCA section 8(d) rules
issued by EPA on October 29, 1996 (61 FR 55871) for the 18 nonylphenol
ethoxylates that were recommended in the ITC's 38th Report and
``stayed'' by EPA on December 11, 1996 (61 FR 65186).
    2. Issue a final TSCA section 8(a) PAIR rule for the 19 nonylphenol
ethoxylates with CAS numbers of the 23 total nonylphenol ethoxylates
recommended in the ITC's 39th Report.
    3. Not issue a TSCA section 8(d) rule for the 23 recommended
nonylphenol ethoxylates in order to allow the ITC the opportunity to
implement its voluntary information submission policy proposed in the
ITC's 40th Report (62 FR 30580, June 4, 1997).
     EPA reserves the right to issue a TSCA section 8(d) rule for some
or all of these 23 nonylphenol ethoxylates if:
    1. EPA believes that such a rulemaking is necessary to gather data
to determine if testing is needed for, or otherwise support the
assessment of, the subject chemical(s); or
    2. The ITC notifies EPA in writing that the ITC did not receive
adequate information via its voluntary information submission activity.
(The ITC's voluntary submission policy can be found on the ITC's
Internet Homepage under Voluntary Information Submission Innovative
Online Network or ``VISION'' (http://www.epa.gov/opptintr/itc/vision).
Hard copies of the ITC's voluntary information submission policy are
available from the TSCA Environmental Assistance Division at the
address listed under ``FOR FURTHER INFORMATION CONTACT.'')

IV. What is the Preliminary Assessment Information Reporting (PAIR)
Rule?

    EPA promulgated the PAIR rule in 40 CFR part 712 under section 8(a)
of TSCA (15 U.S.C. 2607(a)). This model section 8(a) rule establishes
standard reporting requirements for manufacturers (including importers)
of the chemicals listed in the rule at 40 CFR 712.30. These entities
are required to submit a one-time report on general production/
importation volume, end use, and exposure-related information using the
Preliminary Assessment Information Manufacturer's Report (EPA Form No.
7710-35). EPA uses this model section 8(a) rule to quickly gather
current information on chemicals.
    This model rule provides for the automatic addition of ITC Priority
Testing List chemicals. Whenever EPA announces the receipt of an ITC
report, EPA may, at the same time and without providing notice and
opportunity for public comment, amend the model information-gathering
rule by adding the recommended (or designated) chemicals. The amendment
adding these chemicals to the PAIR rule is effective February 10, 2000.

V. Chemicals To Be Deleted

     The following 18 nonylphenol ethoxylates that were recommended in
the ITC's 38th Report are being deleted as a result of today's
revocation of the TSCA section 8(a) PAIR and TSCA section 8(d) rules
that were issued by EPA on October 29, 1996 (61 FR 55871) and stayed by
the Agency on December 11, 1996 (61 FR 65186).

------------------------------------------------------------------------
               Chemical Name                         CAS Number
------------------------------------------------------------------------
        Nonylphenol ethoxylates
alpha-(p-Nonylphenol)-omega-                NA
 hydroxypoly(oxyethylene).
Decaethylene glycol, isononylphenyl ether.  65455-72-3
Ethanol, 2-[2-(p-nonylphenoxy)ethoxy]-....  20427-84-3
Ethanol, 2-[2-[2-[2-(p-                     7311-27-5
 nonylphenoxy)ethoxy]ethoxy]ethoxy]-.
Nonoxynol-2...............................  NA
Nonoxynol-3...............................  NA
Nonoxynol-7...............................  NA
Nonylphenol hepta(oxyethylene)ethanol.....  27177-05-5
Nonylphenol octa(oxyethylene)ethanol......  26571-11-9
Nonylphenol polyethylene glycol ether.....  9016-45-9, 20636-48-0, 26027-
                                             38-3, 26064-02-8, 27177-01-
                                             1, 37205-87-1, 127087-87-0

[[Page 1551]]

Nonylphenol polyethylene glycol ether.....  27177-08-8
Nonylphenolnona(oxyethylene) ethanol......  27986-36-3
Nonylphenoxy ethanol......................  27176-93-8
Nonylphenoxydiglycol......................  68412-54-4
Nonylphenoxypolyoxyethanol................  152143-22-1, 26027-38-3
p-Nonylphenol polyethylene glycol ether...  27986-36-3, 37205-87-1,
                                             98113-10-1
Poly(oxy-1,2-ethanediyl), alpha-            37205-87-1
 (isononylphenyl)-omega-hydroxy-.
Poly(oxy-1,2-ethanediyl), alpha-(2-         51938-25-1
 nonylphenyl)-omega-hydroxy-.
------------------------------------------------------------------------

VI. Chemicals To Be Added

    In its 39th Report to EPA, the ITC recommended a group of 23
nonylphenol ethoxylates. These chemicals can be automatically added to
the PAIR and TSCA section 8(d) Health and Safety Data Reporting rules
unless requested otherwise by the ITC to implement its voluntary
information submission policy. In a letter dated September 15, 1997,
the ITC requested that a TSCA section 8(d) Health and Safety Data
Reporting rule not be promulgated for these 23 nonylphenol ethoxylates.
Therefore, these substances will not be added to Sec. 716.120.
     The regulatory text (Sec. 712.30(e)) of this document lists the 19
nonylphenol ethoxylates that are being added to the PAIR rule as a
result of today's action. The other 4 nonylphenol ethoxylates
recommended in the ITC's 39th report are not being added to the PAIR
rule because they are not associated with unique CAS numbers.

VII. Reporting Requirements

A. Who Must Report Under this PAIR Rule?

    All persons who manufactured (defined by statute to include import)
the 19 nonylphenol ethoxylates identified in the regulatory text
(Sec. 712.30(e)) of this rule during their latest complete corporate
fiscal year must submit a Preliminary Assessment Information
Manufacturer's Report (EPA Form No. 7710-35) for each site at which
they manufactured or imported a named substance. A separate form must
be completed for each substance and submitted to the Agency as
specified in 40 CFR 712.28 no later than April 10, 2000. Persons who
have previously and voluntarily submitted a Manufacturer's Report to
the ITC or EPA may be able to submit a copy of the original Report to
EPA or to notify EPA by letter of their desire to have this voluntary
submission accepted in lieu of a current data submission. See
Sec. 712.30(a)(3).
    Details of the PAIR reporting requirements, including the basis for
exemptions, are provided in 40 CFR part 712. Copies of the form are
available from the TSCA Environmental Assistance Division at the
address listed under ``FOR FURTHER INFORMATION CONTACT.'' Copies of the
PAIR form are also available electronically from the Chemical Testing
and Information Gathering Home Page on the Internet at http://
www.epa.gov/opptintr/chemtest/.

B. Removal of Chemical Substances from the PAIR Rule

    Any person who believes that section 8(a) reporting required by
this rule is not warranted, should promptly submit to EPA on or before
January 25, 2000, detailed reasons for that belief. EPA, in its
discretion, may remove the substance from this rule (40 CFR 712.30(c)).
When withdrawing a chemical from the rule, EPA will publish a rule
amendment in the Federal Register.

VIII. Public Record

    The following documents constitute the public record for this rule
(docket control number OPPTS-82050). All of these documents are
available to the public in the TSCA Nonconfidential Information Center
(NCIC), from noon to 4 p.m., Monday through Friday, excluding legal
holidays. The TSCA NCIC is located at EPA Headquarters, Rm. NE-B607,
401 M St., SW., Washington, DC.
    1. This final rule.
    2. The Economic Analysis for this rule, December 15, 1999.
    3. The 39th Report of the ITC, (62 FR 8578, February 25, 1997).
    4. The 38th Report of the ITC, (61 FR 39832, July 30, 1996).
    5. Stay of the TSCA section 8(a) and 8(d) rules issued in response
to the 38th Report of the ITC, (61 FR 65186).
    6. Letter from the ITC to EPA, September 15, 1997.

IX. Why is this Action Being Issued as a Final Rule?

    EPA is publishing this action as a final rule without prior notice
and an opportunity to comment because the Agency believes that
providing notice and an opportunity to comment is unnecessary. This
final rule makes modifications needed to clarify the identities of
certain chemicals subject to the TSCA section 8(a) PAIR regulations and
removes certain chemicals from the TSCA section 8(d) regulations. EPA
therefore finds that there is ``good cause'' under section 553(b)(3)(B)
of the Administrative Procedure Act (APA) (5 U.S.C. 553 (b)(3)(B)) to
make these amendments without prior notice and comment.

X. Economic Analysis		[SNIP]







From ttweed@wildrockies.org Fri, 14 Jan 2000 22:10:53 -0700
Date: Fri, 14 Jan 2000 22:10:53 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] Hi Prodctn Vol. TSCA petition--comment sought

[Federal Register: January 13, 2000 (Volume 65, Number 9)]
[Notices]
[Page 2163-2164]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr13ja00-67]
-----------------------------------------------------------------------
[OPPTS-00274A; FRL-6487-8]

Voluntary Children's Health Chemical Testing Program;
Cancellation of Public Meeting
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice; cancellation of public meeting.
-----------------------------------------------------------------------
SUMMARY: The public meeting on the Voluntary Children's Health Chemical
Testing Program scheduled for January 19-20, 2000, is canceled. This
meeting was announced in the Federal Register of August 26, 1999 (64 FR
46673) (FRL-6089-1), and was intended to be the third public meeting in
a Stakeholder Involvement Process to develop a voluntary program to
test commercial chemicals to which children have a high likelihood of
exposure. On a future date, EPA will announce a new date for the third
stakeholder meeting and will describe how that meeting will be
conducted. [snip]
============================


from the below:  "...assertions that rules requiring the submission of
existing data provide a better implementation approach for the HPV
Challenge Program and TSCA section 4 HPV test rule(s) than the approach
currently utilized, namely, voluntary submission of existing data..."
---
[Federal Register: January 13, 2000 (Volume 65, Number 9)]
[Notices]
[Page 2164-2165]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr13ja00-68]

-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

[OPPTS-211044; FRL-6487-7]


TSCA Section 21 Petition; Notice of Receipt

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: This notice announces receipt of a petition submitted by five
organizations under section 21 of the Toxic Substances Control Act
(TSCA), and requests comments on the petition. The organizations have
petitioned EPA to initiate rulemaking proceedings with respect to all
chemicals included on the HPV (high production volume chemical)
Challenge Program list as updated through the date of initiation of the
requested proceedings for: The issuance of a TSCA section 8(a)
Preliminary Assessment Information Reporting (PAIR) rule and issuance
of a Health and Safety Data Reporting rule under TSCA section 8(d). The
petitioners further petition that ``[s]uch rule should neither be
limited to participants in the Challenge Program nor exclude substances
or mixtures as to which a participant has enrolled in the Program.''
Under TSCA section 21, the Agency must respond to the petition by March
28, 2000.

DATES: Comments should be received on or before February 3, 2000. The
Agency will accept comments received after that date, but cannot
guarantee that they will be considered prior to preparing its response
to the petition.

ADDRESSES: Comments may be submitted by mail, electronically, or in
person. Please follow the detailed instructions for each method as
provided in Unit I. of ``SUPPLEMENTARY INFORMATION.'' To ensure proper
receipt by EPA, it is imperative that you identify docket control
number OPPTS-211044 in the subject line on the first page of your
response.

FOR FURTHER INFORMATION CONTACT: For general information contact:
Joseph S. Carra, Deputy Director, Office of Pollution Prevention and
Toxics (7401), Environmental Protection Agency, Ariel Rios Bldg., 1200
Pennsylvania Ave., NW., Washington, DC 20460; telephone numbers: (202)
554-1404 and TDD: (202) 554-0551; e-mail address: TSCA-Hotline@epa.gov.
    For technical information contact: Frank Kover, Chemical Control
Division (7405), Office of Pollution Prevention and Toxics,
Environmental Protection Agency, Ariel Rios Bldg., 1200 Pennsylvania
Ave., NW., Washington, DC 20460; telephone number: (202) 260-3946; e-
mail address: ccd.citb@epa.gov.

SUPPLEMENTARY INFORMATION:

I. General Information

A. Does this Action Apply to Me?

    This action is directed to the public in general. This action may,
however, be of interest to chemical manufacturers (including
importers). Since other entities may also be interested, the Agency has
not attempted to describe all the specific entities that may be
affected by this action. If you have any questions regarding the
applicability of this action to a particular entity, consult the
technical person listed under ``FOR FURTHER INFORMATION CONTACT.''

B. How Can I Get Additional Information, Including Copies of this
Document or Other Related Documents?

    1. Electronically. You may obtain electronic copies of this
document, and certain other related documents that might be available
electronically, from the EPA Internet Home Page at http://www.epa.gov/.
To access this document, on the Home Page select ``Laws and
Regulations'' and then look up the entry for this document under the
``Federal Register--Environmental Documents.'' You can also go directly
to the Federal Register listings at http://www.epa.gov/fedrgstr/. In
addition, the petition may also be accessed on EPA's homepage at http:/
/www.epa.gov/chemrtk/sc21main.htm.
    2. In person. The Agency has established an official record for
this action under docket control number OPPTS-211044. The official
record consists of the documents specifically referenced in this
action, any public comments received during an applicable comment
period, and other information related to this action, including any
information claimed as confidential business information (CBI). This
official record includes the documents that are physically located in
the docket, as well as the documents that are referenced in those
documents. The public version of the official record does not include
any information claimed as CBI. The public version of the official
record, which includes printed, paper versions of any electronic
comments submitted during

[[Page 2165]]

an applicable comment period, is available for inspection in the TSCA
Nonconfidential Information Center, North East Mall Rm. B-607,
Waterside Mall, 401 M St., SW., Washington, DC. The Center is open from
noon to 4 p.m., Monday through Friday, excluding legal holidays. The
telephone number for the Center is (202) 260-7099.

C. How and to Whom Do I Submit Comments?

    You may submit comments through the mail, in person, or
electronically. To ensure proper receipt by EPA, it is imperative that
you identify docket control number OPPTS-211044 in the subject line on
the first page of your response.
    1. By mail. Submit your comments to: Document Control Office
(7407), Office of Pollution Prevention and Toxics (OPPT), Environmental
Protection Agency, Ariel Rios Bldg., 1200 Pennsylvania Ave., NW.,
Washington, DC 20460, Attention: Docket Number OPPTS-211044.
    2. In person or by courier. Deliver your comments to: OPPT Document
Control Office (DCO) in East Tower Rm. G-099, Waterside Mall, 401 M
St., SW., Washington, DC. The DCO is open from 8 a.m. to 4 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the
DCO is (202) 260-7093.
    3. Electronically. You may submit your comments electronically by
e-mail to: ``oppt.ncic@epa.gov,'' or mail your computer disk to the
address identified above. Do not submit any information electronically
that you consider to be CBI. Electronic comments must be submitted as
an ASCII file avoiding the use of special characters and any form of
encryption. Comments and data will also be accepted on standard disks
in WordPerfect 6.1/8.0 or ASCII file format. All comments in electronic
form must be identified by docket control number OPPTS-211044.
Electronic comments may also be filed online at many Federal Depository
Libraries.

 D. How Should I Handle CBI Information That I Want To Submit to the
Agency?

    Do not submit any information electronically that you consider to
be CBI. You may claim information that you submit to EPA in response to
this document as CBI by marking any part or all of that information as
CBI. Information so marked will not be disclosed except in accordance
with procedures set forth in 40 CFR part 2. In addition to one complete
version of the comment that includes any information claimed as CBI, a
copy of the comment that does not contain the information claimed as
CBI must be submitted for inclusion in the public version of the
official record. Information not marked confidential will be included
in the public version of the official record without prior notice. If
you have any questions about CBI or the procedures for claiming CBI,
please consult the technical person identified under ``FOR FURTHER
INFORMATION CONTACT.''

E. What Should I Consider as I Prepare My Comments for EPA?

    We invite you to provide your views on the relief sought by the
petitioners, and any data or information that you would like the Agency
to consider in developing its response to the petition. You may find
the following suggestions helpful for preparing your comments:
    1. Explain your views as clearly as possible.
    2. Describe any assumptions that you used.
    3. Provide copies of any technical information and/or data you used
that support your views.
    4. If you estimate potential burden or costs, explain how you
arrived at the estimate that you provide.
    5. Provide specific examples to illustrate your concerns.
    6. Make sure to submit your comments by the deadline in this
notice.
    7. To ensure proper receipt by EPA, be sure to identify the docket
control number assigned to this action in the subject line on the first
page of your response. You may also provide the name, date, and Federal
Register citation.

II. Background

A. What is a TSCA section 21 petition?

    Section 21 of TSCA allows citizens to petition EPA to initiate a
proceeding for the issuance, amendment, or repeal of a rule under TSCA
section 4, 6, or 8 or an order under section 5(e) or 6(b)(2). A TSCA
section 21 petition must set forth facts which the petitioner believes
establish the need for the action requested. EPA is required to grant
or deny the petition within 90 days of its receipt. If EPA grants the
petition, the Agency must promptly commence an appropriate proceeding.
If EPA denies the petition, the Agency must publish its reasons for the
denial in the Federal Register. Within 60 days of denial or no action,
petitioners may commence a civil action in a U.S. district court to
compel initiation of the requested rulemaking. When reviewing a
petition for a new rule, as in this case, the court must provide an
opportunity for de novo review of the petition. After hearing the
evidence, the court can order EPA to initiate the requested action.

B. What action is requested under this TSCA section 21 petition?

    On December 27, 1999, EPA received a TSCA section 21 petition from
five organizations. The organizations have petitioned EPA to initiate
rulemaking proceedings with respect to all chemicals included on the
HPV Challenge Program list as updated through the date of initiation of
the requested proceedings for: The issuance of a TSCA section 8(a) PAIR
rule and issuance of a Health and Safety Data Reporting rule under TSCA
section 8(d). The petitioners further petition that ``[s]uch rule
should neither be limited to participants in the Challenge Program nor
exclude substances or mixtures as to which a participant has enrolled
in the Program.'' Under TSCA section 21, the Agency must respond to the
petition by March 28, 2000.
    Petitioners' request for rules under TSCA sections 8(a) and 8(d) is
based in part upon assertions that rules requiring the submission of
existing data provide a better implementation approach for the HPV
Challenge Program and TSCA section 4 HPV test rule(s) than the approach
currently utilized, namely, voluntary submission of existing data in
connection with the HPV Challenge or as comments to the proposed HPV
rule(s) under TSCA section 4. EPA has commenced a review of this
petition. Comments on the petition may be submitted by any of the
methods identified in Unit I.

List of Subjects

    Environmental protection.

    Dated: January 7, 2000.

Charles M. Auer,
Director, Chemical Control Division, Office of Pollution Prevention and
Toxics.

[FR Doc. 00-850 Filed 1-12-00; 8:45 am]
BILLING CODE 6560-50-F

------------------------------







From ttweed@wildrockies.org Sat, 15 Jan 2000 00:17:07 -0700
Date: Sat, 15 Jan 2000 00:17:07 -0700
From: Tony Tweedale ttweed@wildrockies.org
Subject: [Dioxin-l] Re:Reply

Connie, if it's not obvious by now, my comments below simply weren't aimed
at you.  End of story. (You even seem to have misread my intent on the
residual Cl disinfection Q., as it should have been plainly evident that I
fully agree w/ you that little Cl is needed (if any, actually) and that it
may not be totally effective anyway).  So, jeez, take a breather, relax!)

Another of the radical argument examples I was talking about is the
repeated--almost in passing, but several times--unavoidable implication
that we should average the dioxin TDI's (tolerable daily intakes; "safe"
doses) of various agencies and countries.  This reminds me of Dr Commoner's
complaint of the late '80's EPA dioxin Workgroup trying to average
different estimates from one study of TCDD's cancer potency. Averaging is a
dangerous and logical impossibility in these questions.  If answers aren't
evident, you may have to get into the guts of different claims to decide
which is right, even if it takes decades.  In the case of dioxin TDI's it's
clear which one is based on the most exhaustive, wide-open/inclusive of all
scientists, expansive, complete risk assessment to date--EPA's draft 0.01
pg/kg/d, the lowest one.  None of the other's I've seen mentioned come
within a mile.  Even this most conservative one does not come close to
reflecting our complete exposures or addressing all the health effects data
gaps, nd all the info that's poured in since then gives more cause ofr
concern.  All this puts the averaging suggestion in a different, radical,
dangerous (private interest over public health) light.  Meanwhile the
Precautionary Principle is irrefutable and of great utility to society.
--

>> Some posts from these people have been logical, others not.  >

>Tony, I want to make it clear to you that while I can now see your point,
>that my statement was proffered to debate Davids, not to imply that dioxin
>is safe at some specific level.  I'd like to imagine that I think for
>myself, but I recognize that altogether I worked about 15 years in the
>chemical industry and that I've been inundated with the idea that "the dose
>makes the difference."   I never saw a problem with accepting this concept
>until you questioned my motives.  You wrote: "Other posts from these people
>have similarly been couched in reasonable sounding arguments but were
>actually quite radical arguments--eg that dioxin in the env is safe if at a
>certain level."  This obviously questioned my motives and at first I was
>upset because my motives were on the side of human health, but then I calmed
>down and starting thinking about it.
>
>Connie Hansson
--







From amuller@dca.net Sat, 15 Jan 2000 07:06:40 -0500
Date: Sat, 15 Jan 2000 07:06:40 -0500
From: Alan Muller amuller@dca.net
Subject: [Dioxin-l] Green Delaware Alert # 47--American Cancer Society Lobbyist
 Promotes Philpower Incinerator in Delaware--Calls and emails to Cancer
 Society Needed

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Green Delaware Alert # 47

(please post/forward to friends)

American Cancer Society Lobbyist Promotes Philpower Incinerator

CALLS and EMAILS NEEDED (see below)

Port Penn, DE, January 13, 2000.  Communities in Delaware fight battle 
after battle to protect themselves from cancer-causing incinerator 
pollution.  Philpower Corp., from North Carolina, is trying to put a 
"construction and demolition debris" incinerator in New Castle County, 
DE.  Philpower has hired lobbyist Robert Maxwell (302.777.7445), who also 
works for the American Cancer Society (ACS).  (Maxwell's filing with the 
Delaware Public Integrity Commission calls Philpower an "environmentally 
advanced power company.")

Mission Statement of the ACS (www.cancer.org):

"The American Cancer Society is  the nationwide communitybased  voluntary 
health organization dedicated to eliminating cancer as a major health 
problem by  preventing cancer, saving lives and diminishing suffering from 
cancer, through research, education, advocacy, and service."

Philpower, according to permit applications, would put out as much as ten 
thousand pounds per day of health-threatening air pollutants.  "Total Trace 
Metal Emission," including cancer causing chromium, arsenic, lead, cadmium 
and nickel, would be up to 625 pounds per day (over a quarter of a million 
pounds per year).

Pat Scarborough, ACS "Regional Executive" said: "He does a great job for 
us, what else he does is up to him."  We were not able to get a response 
from ACS national offices.

Maxwell and Philpower President Wayne Coverdale are meeting with 
politicians and offering contributions.  One state legislator returned a 
contribution after finding out who it was from.  Some contributions may 
intentionally be below the $100 reporting limit, but we will publish a 
"dishonor role" of officeholders known to have accepted contributions from 
Philpower.

CALLS and EMAILS NEEDED

The Cancer Society depends on contributions.  Please contact these ACS 
leaders and indicate you WILL NOT contribute to the ACS as long as it uses 
lobbyists who promote incinerators.

John Seffrin, Chief Executive Officer, 404.329.7601, jseffrin@cancer.org
John Kelly, Chair of the Board, jrkelly@cbcgulf.navfac.navy.mil
Pat Scarborough, Regional Executive, 302.324.4227, pscscarbor@cancer.org
Robert Meckelnburg, M.D., Chair, Greater Wilm. Board of Directors, 
302.368.8700, osteorec@prodigy.net

Maxwell also works for the Del. Association of Counties and the League of 
Local Governments.

Contact New Castle County Ex. Tom Gordon, 302.395.5102, FAX 302.395.5268, 
tgordon@co.new-castle.de.us,  and say the County should not employ a 
lobbyist who promotes incinerators.

For more information contact: Alan Muller, Ex. Dir., Green Delaware, 
(302)834-3466
fax (302)836-3005 greendel@dca.net, http//members.dca.net/greendel/  Green 
Delaware will pay for long distances calls opposing incinerators.


*   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *
This is a Green Delaware list.  To be added or removed send email.
We invite feedback on our emissions.
Green Delaware appreciates the support of the Environmental
Endowment for New Jersey
302.834.3466, greendel@dca.net, http://members.dca.net/greendel/

*   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   *   * 
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<html>
<font size=5><div align="center">
Green Delaware Alert # 47<br>
<br>
</font>(please post/forward to friends)<br>
<br>
<font size=4></div>
American Cancer Society Lobbyist Promotes Philpower Incinerator<br>
<br>
</font>CALLS and EMAILS NEEDED (see below)<br>
<br>
Port Penn, DE, January 13, 2000.&nbsp; Communities in Delaware fight
battle after battle to protect themselves from cancer-causing incinerator
pollution.&nbsp; Philpower Corp., from North Carolina, is trying to put a
“construction and demolition debris” incinerator in New Castle County,
DE.&nbsp; Philpower has hired lobbyist Robert Maxwell (302.777.7445), who
also works for the American Cancer Society (ACS).&nbsp; (Maxwell’s filing
with the Delaware Public Integrity Commission calls Philpower an
“environmentally advanced power company.”)<br>
<br>
Mission Statement of the ACS
(<a href="http://www.cancer.org/" eudora="autourl">www.cancer.org</a>):<br>
<br>
&quot;The American Cancer Society is&nbsp; the nationwide
communitybased&nbsp; voluntary health organization dedicated to
eliminating cancer as a major health problem by&nbsp; preventing cancer,
saving lives and diminishing suffering from cancer, through research,
education, advocacy, and service.&quot;<br>
<br>
Philpower, according to permit applications, would put out as much as ten
thousand pounds per day of health-threatening air pollutants.&nbsp;
“Total Trace Metal Emission,” including cancer causing chromium, arsenic,
lead, cadmium and nickel, would be up to 625 pounds per day (over a
quarter of a million pounds per year).<br>
<br>
Pat Scarborough, ACS “Regional Executive” said: “He does a great job for
us, what else he does is up to him.”&nbsp; We were not able to get a
response from ACS national offices.<br>
<br>
Maxwell and Philpower President Wayne Coverdale are meeting with
politicians and offering contributions.&nbsp; One state legislator
returned a contribution after finding out who it was from.&nbsp; Some
contributions may intentionally be below the $100 reporting limit, but we
will publish a “dishonor role” of officeholders known to have accepted
contributions from Philpower.<br>
<br>
CALLS and EMAILS NEEDED<br>
<br>
The Cancer Society depends on contributions.&nbsp; Please contact these
ACS leaders and indicate you WILL NOT contribute to the ACS as long as it
uses lobbyists who promote incinerators.<br>
<br>
John Seffrin, Chief Executive Officer, 404.329.7601,
jseffrin@cancer.org<br>
John Kelly, Chair of the Board, jrkelly@cbcgulf.navfac.navy.mil<br>
Pat Scarborough, Regional Executive, 302.324.4227,
pscscarbor@cancer.org<br>
Robert Meckelnburg, M.D., Chair, Greater Wilm. Board of Directors,
302.368.8700, osteorec@prodigy.net<br>
<br>
Maxwell also works for the Del. Association of Counties and the League of
Local Governments.<br>
<br>
Contact New Castle County Ex. Tom Gordon, 302.395.5102, FAX 302.395.5268,
tgordon@co.new-castle.de.us,&nbsp; and say the County should not employ a
lobbyist who promotes incinerators.<br>
<br>
For more information contact: Alan Muller, Ex. Dir., Green Delaware,
(302)834-3466<br>
fax (302)836-3005 greendel@dca.net, http//members.dca.net/greendel/&nbsp;
Green Delaware will pay for long distances calls opposing
incinerators.<br>
<br>
<br>
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; <br>
This is a Green Delaware list.&nbsp; To be added or removed send
email.<br>
We invite feedback on our emissions.<br>
Green Delaware appreciates the support of the Environmental <br>
Endowment for New Jersey<br>
302.834.3466, greendel@dca.net,
<a href="http://members.dca.net/greendel/" eudora="autourl">http://members.dca.net/greendel/</a><br>
<br>
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp;
*&nbsp;&nbsp; *&nbsp;&nbsp; *&nbsp;&nbsp; * </html>

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From hope@igc.org Sat, 15 Jan 2000 17:15:39 -0500
Date: Sat, 15 Jan 2000 17:15:39 -0500
From: Joy Towles hope@igc.org
Subject: [Dioxin-l] Dioxin in waterways lawsuit in California

>
>                       Lawsuit Filed Over Tainted Waterways
>
>                       Bernadette Tansey, Chronicle Staff Writer
>
>                                                                            Friday, January 14, 2000
>
>
>
>                       Regulators have allowed more than 500 California waterways to
>                       become contaminated over the past 20 years while failing to set
>                       pollution standards required by the Clean Water Act,
>                       environmentalists charged in a lawsuit against the federal
>                       government.
>
>                       The coalition of environmental groups is asking a federal judge in
>                       San Francisco to force the U.S. Environmental Protection Agency
>                       to speed up deadlines for setting limits on the discharge of
>                       pollutants like dioxin, polychlorinated biphenyls (PCB's) and
>                       mercury.
>
>                       Felicia Marcus, EPA's regional administrator for Northern
>                       California, traced the delays to insufficient funding supplied to the
>                       state water boards. The federal government has delegated the
>                       boards to carry out the Clean Water Act in California.
>
>                       ``Adequate resources were not allocated to do this work,'' Marcus
>                       said. But she said Gov. Gray Davis' administration has been more
>                       willing to tackle the job. Progress is being made, but the process is
>                       time-consuming, Marcus said.
>
>                       The Clean Water Act calls for individual assessments of each
>                       contaminated waterway to determine the maximum amount of each
>                       harmful pollutant it can absorb daily without, for example, making
>                       water unhealthy to drink or fish unsafe to eat. Limits are then
>                       placed on industries and other polluters based on those
>                       calculations.
>
>                       The standards, once set, could not only limit releases from
>                       refineries and other large dischargers, but could also restrict such
>                       things as household lawn pesticides.
>
>                       The federal suit filed Wednesday alleges that 102 different
>                       contaminants have degraded drinking water, fish habitats, or other
>                       beneficial uses of state waterways, including San Francisco Bay
>                       and the Sacramento-San Joaquin River Delta.
>
>                       Congress set a 1979 deadline for the creation of standards for the
>                       total amount of contaminants that could be released daily into
>                       threatened waterways, said Mike Lozeau, an attorney representing
>                       WaterKeepers Northern California, its projects San Francisco
>                       BayKeeper and DeltaKeeper.
>
>
>                                                                             Get a printer-friendly version
>                                                                             of this article
>
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>
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>
>
>
>
>                       ©2000 San Francisco Chronicle   Page A20
>
>
>
>