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Re: E-M:/ EPA, MDEQ UPDATE ON PERMIT STATUS OF MICHIGANDISPOSAL WASTETREATMENT PLANT -Reply



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Enviro-Mich message from "MICHAEL W. MURRAY" <MURRAY@nwf.org>
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Dave and others interested in PCBs:
	Apologies for the late reply on reporting on PCBs. I'm not
sure that DEQ is necessarily engaging in a little legerdemain on the
reporting issue. I know that Wisconsin for awhile in the 1980s was
doing routine monitoring for PCBs using the older analytical technique
which did not resolve the individual congeners, and thus they could
only really attempt to report total PCBs, as Aroclor equivalents. This
is not ideal, because of the transformations in the environment that
you write about, and the fact that it is a crude analysis for a
complex mixture, but I assume it was practiced by all states (to the
extent that they were monitoring PCBs at all) until fairly recently. 
	To get a real good estimate of actual toxicity and
concentration trends, ideally you would have data for the most
problematic congeners, as you discuss, or even as many individual
congeners as possible. But the former requires a sophisticated
technique (multidimensional gas chromatography) that I presume is not
routinely used for monitoring in most states, although it probably
should be. The latter analysis (getting good data on maybe 70-80
congeners) is fairly routine, although again, I don't know to what
extent standard capillary column GC is being used by the states in
monitoring. Using data from individual congener analysis, one can also
sum up to get total PCB concentrations, and/or convert to toxic
equivalents (in terms of similarity to 2,3,7,8-TCDD), and then look at
trends, if you don't follow individual congeners directly.
	In terms of trends, all studies that I am aware of looking at
PCBs in fish and water in the Great Lakes have shown decreases since
the 1970s, which is consistent with the fact that PCBs were phased out
of new uses by 1977. (Again, there is very limited information on
trends following individual congeners, although data for Lake Superior
follow the same trend). However, the decreases have been much less
pronounced in many cases since the mid-1980s, reflecting in part the
nature of declines following a phaseout, the persistence of PCBs,
remobilization of historic sources (in sediments, etc.), releases of
PCBs from existing sources (older transformers and capacitors,
landfills, and new generation in some incinerators - emissions which
can then be deposited on lake and land surfaces), and possibly food
chain changes (in terms of fish concentrations). In addition, one of
the main mechanisms of loss for the Great Lakes has been
volatilization to the air, so that apparent improvements in PCB levels
in the Great Lakes (decreases) is in part accompanied by additional
contamination somewhere else. 
	Just wanted to point these things out. But I still agree that
the fact that PCBs are so persistent and have documented ecological
and human health impacts indicates the need even 20 years after their
phaseout in the U.S. to properly deal with ways to reduce or eliminate
any new releases, as well as exposures from both new and historic
sources.

        Mike
        NWF

>>> "david zaber" <dzaber@gateway.net> 11/13/98 12:42pm >>>
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Enviro-Mich message from "david zaber" <dzaber@gateway.net>
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This is a great reflection of the corruption and anti-scientific
positions
of Michigan's DEQ under Engler (well, not exactly under Engler since
that
would cut off the staff's air supply).

In layperson's terms: Let's take a toxic material that causes a wide
range
of human health and ecological impacts and bring it into the watershed
of
the world's most important freshwater resource.  And don't forget to
weaken
the fish consumption standards for the same toxic materials so that
when it
eventually reaches the lakes (and it will), we can fool the people
into
believing it is not hazardous.  

Oh, one more thing.  When reporting on the concentrations of PCBs, use
the
outdated commercial classification, Aroclor, for reporting purposes. 
That
way, one can point to a decline in total PCB concentrations when
touting
the Governor's environmental record (or when lying about the
Governor's
record, you decide which wording is more appropriate).  Why is that?

Let me briefly explain.  First, Aroclor is the trade name Monsanto
used for
their commercial PCB products.  The Aroclor name was followed by four
numbers, ie. Aroclor 1248, Aroclor 1254, etc.  The first two numbers
represent the presence of two phenyl rings.  The second number
represents
the approximate percentage of chlorine in the Arochlor mixture; the
higher
the number the more viscous or thick the PCB product.  

However, PCBs are a family of compounds that are different from one
another
as a result of the number and position of the chlorines attached to
the
phenyl rings.  Thus, there are approximately 200 theoretical PCB
congeners
out there (congeners is loosely translated as "same genus" or same
chemical
with slightly different construction).  However, there are only a
handful
of PCB congeners which are actually problematic for living things and
the
environment.  These are the ones which mimic the actions of dioxin,
but
there are other toxic effects as well, both dioxin-like and unlike
dioxin.

The problem is, the composition of the Aroclor changes as the material
is
processed by the environment and moves up the food webs. 
Specifically, the
higher chlorinated congeners (those with 7 and 8 chlorines, mostly)
pretty
much sit there in the environment and do not move up the food web
readily. 
The lower chlorinated congeners can be broken down more readily by
biotic
and abiotic processes and thus do not seem to accumulate to a great
extent
in many cases.  However, the middle group, those with 4, 5 and 6
chlorines,
are the most toxic and are the most likely to bioaccumulate.  

As a result of the differential environmental and biological behavior
of
the various PCB congeners, the composition of the PCB contamination
profile
in fish and higher organisms is different from the composition of the
originally discharged Aroclor mixture.  

BUT, and this is a big BUT.  The regulatory agencies such as MDEQ
(when
they are not bending over for Engler's corporate sponsors) report the
concentration of PCBs in fish, for example, as total Aroclors.  They
do not
break down the composition of the contaminant in the fish to more
accurately reflect the potential biological hazard of these poison
fish,
despite the fact that they may be vastly different then the original
Aroclor mixture.  By doing things in this way, MDEQ can say that
overall
concentrations of PCBs may have decreased and they use this to
cynically
bolster the enviro credentials of Engler and his cronies.  However,
because
the composition of PCBs in the fish is comprised of a greater
proportion of
the more toxic congeners, the toxicity of the fish may actually be
higher
then one is lead to believe by the Aroclor number alone.  



David John Zaber
904 Glaizewood Court
Takoma Park, MD 20912
dzaber@gateway.net

----------
> From: GREGORY RUDLOFF <RUDLOFF.GREGORY@EPAMAIL.EPA.GOV>
> To: enviro-mich@great-lakes.net
> Subject: E-M:/ EPA, MDEQ UPDATE  ON PERMIT STATUS OF MICHIGAN
DISPOSAL
WASTETREATMENT PLANT
> Date: Friday, November 13, 1998 9:22 AM
> 
>
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> Enviro-Mich message from GREGORY RUDLOFF
<RUDLOFF.GREGORY@epamail.epa.gov>
>
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> 
> U.S. EPA REGION 5 NEWS RELEASE
> -------------------------------------------
> 
> Media Contact: Denise Gawlinski
> (312) 886-9859
> 
> For Immediate Release: November 12, 1998
> 
> No. 98-OPA344
> 
> EPA, MDEQ TO UPDATE PUBLIC ON PERMIT STATUS OF MICHIGAN
> DISPOSAL WASTE TREATMENT PLANT; AVAILABILITY SESSION DEC. 2
> 
> U.S. Environmental Protection Agency (EPA) Region 5 and Michigan
Department of
> Environmental Quality (MDEQ) will hold an availability session to
update
the public on
> the status of the draft hazardous waste operating license and permit
for
the Michigan
> Disposal Waste Treatment Plant, Belleville, MI.
> 
> The session will be held Wednesday, Dec. 2, from 6 to 9 p.m.,
Belleville
High School,
> 501 West Columbia, Belleville.
> 
> EPA and MDEQ representatives will be available to answer questions
on
their review
> of the draft license and permit.  The plant has continued operation
as a
hazardous
> waste treatment facility under its existing license and permit.  
> 
> In April 1997, EPA and MDEQ renewed an operating license and permit
to
Wayne
> Disposal, Inc., for its hazardous-waste landfill.  Both Wayne
Disposal
and Michigan
> Disposal Waste Treatment Plant facilities are owned by Environmental
Quality Co.,
> and are located at 49350 North I-94 Service Dr., Belleville.  
> 
> EPA and MDEQ also granted approval for the landfill to accept
polychlorinated
> biphenyl (PCB) waste.  The agencies evaluated and responded to
hundreds
of public
> comments before making decisions.
> 
> EPA and the State decided to delay decisions on the draft license
and
permit for the
> treatment plant until Wayne County Air Quality Management Division
and
the facility
> resolved air permit issues.  Wayne County is holding a public
hearing
Nov. 19 at
> Belleville High School to take comments on its proposed consent
agreement
with the
> facility on alleged air violations.  Wayne County staff will also be
present at the Dec. 2
> session.
> 
> Site-related documents are available for review at information
repositories at
> MDEQ's Southeast Michigan District Office, 38980 Seven Mile Rd.,
Livonia;
Fred C.
> Fischer Library, 167 Fourth St., Belleville; and Van Buren Township
Hall,
46425 Tyler
> Rd., Belleville. 
> 
> ##
> 
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