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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 "david zaber" <dzaber@gateway.net>
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Carbon Column chromatography and other forms on congener specific analysis
have been around for years and should be standard monitoring practice for
all states and the feds.  Simply because a monitoring technique is
expensive is not sufficient reason for not using it (which I am sure Mike
M. will agree with).  After all, think of the costs to us all of the
ongoing contamination of our environment by these toxic pollutants.  Until
then, I'll stick with the mink test: When the mink can eat fish without
adverse effects, I'll feel comfortable doing so.  Until that time, I'll
leave the fish on the shelf (or in the water as the case may be).

The decline in PCBs that Mike mentions is exactly the type of data that can
confuse.  While the total PCB levels decline, their toxicity in living
things may indeed be increasing.  Without a comprehensive set of biotic and
analytical monitoring approaches, we are bound to miss important
information on the quality of our environment.

Finally, there are estimates that only about 10% of the total amount of
PCBs on earth have been released to the environment so far. If that is
true, then we have serious problems awaiting us in the near future.  Thank
God we are not marine mammals, they don't have the proper metabolic enzymes
to even begin to breakdown their PCB loads.  Thus, they pass on huge
amounts to their young and accumulate high levels themselves.


David John Zaber
dzaber@gateway.net

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> From: MICHAEL W. MURRAY <MURRAY@nwf.org>
> To: Enviro-mich@great-lakes.net
> Subject: Re: E-M:/ EPA, MDEQ UPDATE  ON PERMIT STATUS OF MICHIGANDISPOSAL
WASTETREATMENT PLANT -Reply
> Date: Sunday, November 22, 1998 1:28 PM
> 
> -------------------------------------------------------------------------
> Enviro-Mich message from "MICHAEL W. MURRAY" <MURRAY@nwf.org>
> -------------------------------------------------------------------------
> 
> 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 >>>
> -------------------------------------------------------------------------
> Enviro-Mich message from "david zaber" <dzaber@gateway.net>
> -------------------------------------------------------------------------
> 
> 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
> > 
> >
> -------------------------------------------------------------------------
> > Enviro-Mich message from GREGORY RUDLOFF
> <RUDLOFF.GREGORY@epamail.epa.gov>
> >
> -------------------------------------------------------------------------
> > 
> > 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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