Document 5kmEMM8NQbepV402K2r7bmN38

From the d esk o/ GEORGE ROUSH, J R .> M, D 7/27/83 M. C. Throdahl When we took the Nitro EPA data to the Governor's office, that office contacted the West /Virginia University for advice. This letter is an attempt to help the University respond to the Governor's request. Monsanto Monsanto Company 8 0 0 N. Lindbergh Boulevard St. Louis. M isso u ri 63167 Phone: (314) 6 9 4 -1 0 0 0 July 27, 1983 Dr. E. Gordon Gee President West Virginia University Morgantown, West Virginia 26506 Dear Dr. Gee: I am writing to tell you of the dioxin health issue as faced at the Monsanto Nitro plant and by the community. Satisfactory handling of this issue is important to Monsanto, to Nitro and to West Virginia, and the issue demands the best that medical science and chemistry can bring to this many-faceted subject. As a means of enlisting the input of the many disciplines at the West Virginia University, I would propose to describe the issue to a committee selected from the University. I would bring with me a chemist and a production engineer from the plant to present the back ground and to answer any questions. The committee could then decide what inputs the University would want to contribute to the issue as they believe appropriate. If a chairman of the University committee were appointed, I would help him to select disciplines to be represented on such a committee and would help him to arrange an early time for his. meeting. If I am told who is selected as chairman, I will then begin to help him bring to gether the committee. If this possible approach to bringing the University into this issue seems reasonable, I will be happy to assist the chairman. If there are other possible approaches, I would also be anxious and willing to dis cuss them if that seems appropriate. I can be contacted at (314) 694-8800. Thank you for your obvious interest and willingness to help. GR:hc bec D. S. Frazer - Nitro W. J. McCarville santo Monsanto Company 8 0 0 N. Lindbergh Boulevard St. Louis, M issouri B3167 Phone: 314) 594-1000 June 22, 1983 DEPARTM ENT O F MEO, ENVIRONMENTAL 1 . ^ . . . Hon. James A. Finch, Jr. Chairman, Governor's Dioxin Task Force 404 Capitol View Terrace Jefferson City, Missouri 65101 Dear Judge: As we have had presentations on the disposal of dioxin wastes, I have brought back the handouts for review by appropriate experts within Monsanto. Included in this group was James A. Peters from our Dayton Laboratory, who has been a consultant to the EPA on incineration. Mr. Peters has just written to me with his comments on some of these proposals, and I am sending a copy of his letter to you for whatever use you may have for these comments. If you think it appropriate, you may give a copy to the Department of Natural Resources. Part of my reason for giving this information to you is that if there are questions from either your sub-committee on disposal or by the DNR, they should feel free to contact Mr. Peters at the telephone number as shown on his letterhead. On another subject, I saw a letter to the editor by Bob Powell, who was writing on the subject of dioxin panic, and he addressed his comments to the Wall Street Journal. His letter to the editor is enclosed. I have also enclosed a copy of the "Dioxin Hysteria" editorial. Sincerely /h e E n d s. CC J. A. Peters J. D. Wilson U CQ4171 . . ~ Dayton Laboratory 1515 Nicholas Road P, O. Box 8, Station B Dayton, Ohio 45407 Phone: {513) 265-3411 TWX 810-459-1681 17 June 1983 Monsanto Company George Roush, M.D. Director DMEH 800 N. Lindbergh Blvd. St. Louis, Missouri 63167 Dear Dr. Roush: I have reviewed the Dioxin Waste Disposal Proposals prepared for the Governor's Dioxin Task Force, Missouri Department of Natural Resources. The best method of evaluating these diverse proposals is to respond synoptically to' each, and follow with my recommendation. ^ Acurex Waste Technologies, Inc. Acurex only wants-to (and is capable of) treating the solvent wash concentrate from the soil extraction process. Another contractor (CH2M Hill) will excavate and solvent extract the affected soil. Washing tests on only lOOg soil have shown 99% TCDD extraction but 3-4 ppb TCDD still remain with the soil -- this may still be excessive. Soil washing technology is rife with problems begging for technical solutions, e.g.: Because efficiency of soil extraction depends on the surface area (soil) / mass (solvent) ratio, pulverization and drying (to remove 25% moisture) are necessary. Each of these pretreatment steps have air emissions problems. Moreover, the best solvents for dioxin are toluene, aromatic naphtha, and methylene chloride; toluene and methylene chloride are likely to be classified as hazardous air pollutants by EPA in future rule-making. o Separation and concentration of the washed soil involves filter pressing and drying; these operations are equipment intensive and must include emission control. o Concentration of the wash solvent after extraction involves take-over distillation (energy intensive) for solvent recycle. Again, another process step which must have emission control. a subsidiary of Monsanto Company To: George Roush, M.D. 17 June 1983 Page 2 Lastly, the resultant solvent concentrate could just as easily be incinerated for ultimate disposal as destroyed by the Acurex chemical process. Critical Fluid Systems, Inc. This firm is promoting the supercritical fluid extraction process, which is currently only a pilot scale process. This means unproven technology and impossible-to-estimate costs. Consequently, they propose only a small-scale test program, which, even if successful, does not guarantee their management and equipment ability to handle the super large scale disposal job at hand. University of Missouri-Columbia They want to study and study and study the technical approaches and migration/fate. They will probably become involved in the research mode of the disposal process anyway. Midland-Ross They have the requisite soil decontamination experience through years of U.S.,Army research and application, e.g., their facility at Tooele, Utah. They also had success with Kepone-contaminated'soil incineration for EPA, but did not get the acclaim they felt was deserving. Understandably they maintain their proprietary and client confidentiality positions with respect to the Missouri problem. For this reason, they are wary of a fishbowl project environment. Law Engineering Testing Company I cannot evaluate what they are able to offer based on their letter. Rol1ins Environmental Services - Deer Park, TX They provided the most thorough technology assessment of the disposal alternatives, and have extensive operating experience in most of today's proven disposal techniques. They correctly identify the cost-intensive and time practicality constraints associated with direct feeding of soil to conventional incinerators. Similarly, they identified the unsolved technical problems of solvent extraction followed by chemical or thermal destruction, as well as most land-based disposal options. Rollins advocates building an aboveground secure landfill with gravitational-force leachate collection and treatment system. They offer compelling points to consider: o They correctly point out the decreased cost and time advantages for "ultimate" disposal by aboveground closure. To: George Roush, M.D. 17 June 1983 Page 3 This remedial alternative has been successfully used before, e.g., the 800 acre vault constructed by Canonie-D1Appolonia for Hooker Chemical in Montague, Michigan for hexachlorocyclopentadiene wastes. o The resultant landfill would be a pyramid-shaped "monument0 | to man's past stupidity associated with contaminating these ' areas-- this can be viewed in a beneficial or derisive light ' (my comments). . Aboveground closure provides access and opportunity for in situ testing of biological degradation of dioxin in landfills. Aboveground closure can be designed to incorporate a bacterial seeding and nutrient circulating system to speed degradation. Separate cells can be constructed to test a multitude of bacteriological systems. What a great opportunity to test and publicize "superbugs" and genetic engineering to achieve hazardous waste destruction vis a vis the public impression that dioxins are stored in "the monument" in saecula saeculorum. My Recommendation Allow me to preface that what follows is only my opinion. The best technical solution proposed from what is contained in the file is the aboveground closure technique. Obviously, the social and political whirlwinds associated with siting such a "monument" are immense, but any alternative will have furjous siting problems. Rollins has prepared the most comprehensive proposal of the lot, have proven technology on their side, and offer the best cost and time estimates. Thank you for the opportunity to comment on these proposals. Sincerely, JAPrged James A. Peters Air/RCRA Specialist/ESC THE WALL STREET, JOURNAL, MONDAY. JUNE 20, 1983 Letters to the Editor ' DioxinPanic Poisons Our Judgment " Your penetrating editoriaI *'Dioxin Hys* pays the bills? We all do. of course. So it teria*' (May 31) provided a sense of bal- behooves those who m ake-the judgments ance- and perspective that has been sadly' ' about'risks and benefits and costs to m ake lacking in news coverage of Times Beach them carefully, unswayed by the hysteria and other areas. rV ': ; 'of the moment or the hyperbole on whichr it W h ile I agree with your conclusion that ` thrives. ''' V vtfiat Is known suggests that "m'ost of the . .John W. Hanley spare stories are exaggerated," I feel It . 1 -Chairman would have' been still more useful to point * . Monsanto Co. ojjt that the costs of this exaggeration and St. Louis * .' * . the resulting- hysteria have been stagger- *** irig and are likely to haunt us for years. * '. ' The high cost of hysteria to date is re- "Dioxin Hysteria" justifies as* w ell as fleeted, for example, in the Federal Gov- sets an example of its title. There was se- ernment's 533 million buyout of Times lective use of facts and scientific studies. A Beach, and in extravagant jury awards close reading of the.Nltro, West Virginia, such as the 558 million judgment in a tank- study will show the persistence of chlor- .car spill in Madison County, Illinois, where- acne four years after the exposure. Evi- the plaintiffs were not even-shown to have * dence'linking liver enlargement to expo- suffered any ailments directly attributable . sure* can be found in this study and in the to, the; spill. 7. ' / r \. ,- report of the Council on Scientific Affairs ^ These examples are only a dismal pre- ' of the American Medical Association, also lude unless reason and ' knowledge are referenced in the editorial. - brought to bear on societal questions o f Dioxin In the environment does not just this kind. Hysteria and fear are poor sub- go aw ay-m ost of the Missouri sites w e r e ; statutes for rational decision-making on contaminated a dozen, years a g o -a n d to public issues affecting, the health, safety effectively deal with It, reasoned measures and livelihood of millions of Americans. must be taken, i The best way-Indeed, the only sensible P rof. R.L. P owell way--of coping with the increasingly com- Member, Governor's .Task- plex and costly decisions we face in this .. Force on Dioxin area is through objective evaluation of the Washington University risks and benefits involved. Who ultimately St. Louis . . . ' \ 1T" Dioxin Hysteria T H E W ALL STREET JOURNAL. TUESDAY, MAY 31, 1983 ; REVIEW & OUTLOOK i Hardly a day goes by without some impaired. No derangement of gesta- frightening headline about dioxin-or tion, no fetal lethality and loss, nc more precisely, 2,3,7,8-tetrachlorodi- gross malformations, no gross retar- benzo-p-dioxin,, one of 75 dioxins. This dation at term and no cytogenetic a b is reported as the most toxic chemical normalities have yet occurred." ] made by man. Its presence in drain* ' It's too early to tell whether the age ditches was one of the principal, residents of Seveso face a higher risli reasons families near Love Canal of cancer as a result of their expo abandoned their homes. The federal sure, but studies of another dioxin ac- government bought out the town o f cident more than 30 years,ago suggesi Times Beach, Mo., after the Center that this threat may be overblown. Ir for Disease Control recommended 1949, there was an explosion at an- evacuation at exposures above one other trichlorophenol plant, this ont part per billion in soil samples, owned by Monsanto in Nitro, W.Va, Traces of the toxin have been found in . Soon afterward, 121 workers-con fish. And more than 16,000 Vietnam tracted chloracne. In 1980, the Journal veterans have filed disability claims of Occupational Medicine published a attributing skin disease, baldness, im study by a Monsanto scientist and by potence, cancer and their children's the director of the University of Cin birth defects to the dioxin in the defo cinnati Institute of Environmental liant Agent Orange. The conventional Health, tracking the medical liistories wisdom was aptly summed up in the of those 121 workers through 1978. The title- of a recent New York news authors discovered no abnormal inci show--"Dioxin; In Search of a dence of cancer, and in fact the work Killer.". " ers were on average living longer Clearly, there are reasons to be than would be/expected from theii worried about the stuff. High concen age, race and sex distribution. trations in the soil-30,000 times The Air Force has been conductin' greater than the CDC evacuation stan an epidemiological study of the dard-killed horses at Times Beach. "Ranch Hands" who were directly in In the laboratory, low doses in the volved in spraying Agent Orange ir daily diet have led to increases in Vietnam; of all Vietnam veterans liver cancer among rats, to birth de they were presumably the most ex fects s u c h -a s' cleft palates among posed to dioxin. Of the 67 deaths mice and to abnormally high numbers among the Ranch Hands so far, only of miscarriages, as well as anemia three- are attributable to cancer, a and hair loss among monkeys. The lab lower *proportion of cancer-causec results vary enormously by species: deaths than in the control popula Dioxin appears to be about 5,000 times tion. more toxic for guinea pigs than ham The Environmental Protectior sters. Since it would be unthinkable to Agency now bans the spraying of tht conduct laboratory experiments on dioxin-contaminated herbicide, 2,4,5 people, researchers really don't know - T," on forests, pastures and-rights oi at what dose it becomes dangerous for way. It based its suspension decision humans. on a study attributing to 2,4,5-T an ab What is known, however, suggests normally high number of miscar that most of the scare stories are ex riages in the area around Alsea, Ore., aggerated. Human exposure to dioxin in 1976. The EPA Alsea study has has so far been scientifically linked to since been discredited by 18 separate only one health problem -a skin dis investigations. In particular, a stud} ease called chloracne, which tends to by the Environmental Health Sciences go away fairly rapidly. This is true' Center of Oregon State Universit} even at fairly high exposure levels. concluded in 1979 that the "rate oi We have some real experience with spontaneous abortions in the study 'dioxin, resulting from major acci area does not appear to be related tc dents, in particular the infamous ex the use of 2,4,5-T." plosion of a trichlorophenol plant in None of this means that dioxin is Seveso, Italy, in 1976. More than 700 harmless. Certainly toxic chemicals people were evacuated from Seveso, should be carefully controlled, and ac and 181 contracted chloracne. So far, cidental releases should be carefully however, no serious medium-term monitored. But there are a lot of other health problems have been discov threats to worry more about, such as ered. according to a report last year tobacco, marijuana, drunk driving or by the Council on Scientific Affairs of street crime, where the evidence of the American Medical Association. threats to health is d ea r. The notion "The mild chloracne, which occurred that dioxin is a doomsday menace is mainly in a small group of children, based less on medical evidence than healed quickly. . . . Except for the on some kind of psychological phe skin, no organs or body functions were nomenon. anto tROM [NAUG L C C A liQ ^ -P H O N tl Dept, of Medicine & Environmental Health G. Roush, J r . G2WG 8800 June 21, 1983 cc PROTOCOLS FOR EPIDEMIOLOGIC STUDIES OF THE HEALTH OF VIETNAM VETERANS TO'. M. c * Throdahl DID A great deal of effort has been expended in these protocols to ensure that an effect, if due to dioxin, will be detected. They will look for effects which have been identified by animal studies as well as by a variety of human studies and they acknowledge that there is still the real possibility they will have false positives, false negatives, and also equivocal findings despite this effort. I like the stated recognition that these protocols will be developmental and may change with time, but they do not state how they will be able to handle the biases if they later change protocols. If they change protocols, biases will be difficult to control. In any of their three cohort studies, including "likely exposed" may identify a cohort with more combat duty, and with this selection there may be increased deaths, increased casualties, or even increased drug usage. This possibility is not considered in the protocol - maybe they can identify this possibility by comparison to the "likely not exposed", or even to cohort 3. World War I had its "gassed syndrome", World War II had its battle fatigue and tropical diseases, and Vietnam had its drugs and other known confounding factors. I believe that the definition of cohorts in St. Louis should prevent biases, but the examinations of the veterans can be biased by the questioners, by the physical examiners, or even by those who decide they want to take the exams. From what 1 know of Ranch Hand, I believe that these possible biases have been well handled. I now would like to list some of my specific comments for the various pages of this protocol: Page 8, first paragraph. It states that it is possible that a significant exposure was from non-Ranch Hand applications. They do not give the basis for this statement and it would seem that this could not be a major source of exposure. Page 9, second paragraph. It states that for the occupational exposure, the total number of exposed persons was usually not reported, but, in fact, this exposure list is recorded in a number of books and summaries. I believe this paragraph should also address the fact that 2,4,5-T was used widely and indiscriminately over a number of years in the United States and without reported effect over these many years. Page 10, first paragraph. This paragraph talks about liver effects, but it does not acknowledge or recognize that these liver effects were temporary in practically all reported cases. im t n M /o c w C04173 M. C. Throdahl June 21, 1983 Page 2 Page 11, the last paragraph. The statement is made that literature suggests that Vietnam veterans differ from other veterans in a number of ways. This protocol does not state how they will deal with these many confounding factors. Page 12, second paragraph. It states that the servicemen enjoyed better long-term health than their counterparts who did not serve in the military. I suspect that they are dealing with the so-called healthy worker effect. Nevertheless, a comparison between the military and non military would be an interesting definition of long-term health status. Page 12, last paragraph. The first sentence states that there are no studies comparing the health of combat veterans with those who did not i participate in combat. I would think that the reason there are not reports is that those in combat did not suffer effects other than those who were not in combat. This would account for why there are not reports. Page 17, ninth line from the bottom. It states that if differences existed and they applied to all veterans, then a valid study of Vietnam experience would not be possible. I don't see how they reach such a conclusion; if there is no difference seen, then there is not a Vietnam effect. Page 18, second paragraph, fifth line. They are discussing the Swedish finding of soft tissue sarcomas but they fail to address the negative studies done similarly to the Swedish studies which found no effect. These studies include the Finnish and the New Zealand studies. See ' 1 attached analysis. Page 18, fourth from the last line on second paragraph. They state that other cancers could be added easily if an association was suggested. Based on a form of this lymphoma study, I don't see how the other cancers could be identified. Page 35, first paragraph. This paragraph implies that the Swedish study has established an effect between the exposure and sarcomas. I have no problem with them attempting to prove Hardell's conclusions, but I do not believe that Hardell's conclusions are fact. I see no reason for not in cluding cases which arose prior to 1984 as a part of the soft tissue sarcoma study. Again, see same attached analysis. Page 44, first paragraph. This paragraph states that more emphasis will be given to dermatologic and immunologic studies for the Agent Orange cohort and for psychologic outcomes for the Vietnam cohort. Such an approach would encourage bias. The interviewer should not know which group an individual is in. A standard protocol should be used which would be constant, regardless of the response of the individual. Page 44, second paragraph. It states that all the factors may be associated with service in Vietnam. They are indeed correct and these same confounders will be found not only in the non-service cohort but also in the Agent Orange cohort as well. M. C. Throdahl % w June 21, 1983 P$ge 3 Page 44, third paragraph, fourth line from bottom. Though the subject's perceptions about*exposure to herbicides are indeed appropriate, the same question should be addressed to the "exposure unlikely cohort" as well as the third cohort. After receiving replies to these questions, the remainder of the questionnaire should be followed just as though there had been no discussion of exposure to herbicides. Only in this way will biases be prevented. Page 46, paragraphs one and two. There is no question but that servicemen with complaints will be more likely to participate in the study than a man without complaints. This will create a bias. This section does deal with the importance of well-standardized, non-biased approaches and it certain ly is well stated. Page 71, first paragraph. Though it states that this high risk is generally suspected to be exposure to Agent Orange, one of the reasons CDC has been asked to do the study is that many experts do not think that ex posure to Agent Orange produces risk. Nevertheless, it is the possibility of high risk that is the basis for this study by the CDC. As stated earlier in the protocol, there are many other factors which are, not may have been, factors which can confer an increased risk. The last sentence in this paragraph acknowledges that being in Vietnam poses health risks which should be identified. /he Attach. V>