Document YrMkDdeG4k4nVor4RXBev42mN

p i :# Dioxin; A Toxicology Concern & The EPA Dioxin Documents Peer Review meeting was held in Cincinnati, Ohio on August 27, 28 and 29th. The three-day meeting lasted over a week in the news reports published in many areas of the country. Although billed as a technical meeting, the news reports gave the topic more of a political than technical flavor. The EPA Dioxin Documents deal with fate, transport and toxicology although most technical focus is on toxicology. Only two reviewers, Louis Thibodeaux and Ralph Nash, out of a panel of 30 scientists are technically qualified to discuss fate and transport. -The remaining 28 technologists were there to discuss the toxicology"of the dioxins. This lopsided emphasis is hard to understand since the fate and transport mechanisms must be known to fully characterize human exposure concerns. If in fact the dioxins of concern are destroyed prior to human contact the toxicology concerns are of questionable importance. Based on newspaper accounts of the meeting the concentration of concern in water was reduced from 2.1 parts per quintillion (2.1x10"^) to 21 parts per hextillion (2.1x10"^ ) . This is equivalent to 4 molecules per milligram of water to 4 molecules per 0.1 grams of water. Level at which analytical detection is hard to visualize. At this time politics is dictating action on 2, 3, 7, 8 TCDD and other dioxins. When the cost of dealing with these irrational levels are defined, hopefully good science will be used to define control requirements. G C18581 /it CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. Jerry M. Schroy MONTHLY STATUS RFPORT J. M. SCHROY APRIL 1983 SUBMITTED MAY 6 1963 CONFIDENTIAL SUBJECT TO PROTECTIVE' ORDER, 1. QEMgL8gMEMIgFQJECI LQBil . " CEA-frrfl^&E-jLQ3^PLACE_EX.EQSUB--C^LlIS&L ......... AWAITING COMMENTS ON TWO GUIDELINES AT THIS TIME. ACTIVITIES MINIMAL DUE TO EFFORT FOR ENVIRO-CHEM AND DELAYS IN CHANGES IN THE"RESOURCE DIRECTORY DUE TO ADDED PERSONNEL MOVES WITHIN CED. ADDITIONAL MOVES IN MAY AND/OR JUNE ARE EXPECTED FOLLOWING THE "LATEST REORGANIZATION CAUSING FURTHER DELAYS IN THE DIRECTORY REVISION.________________________________________________________ _ c l a _b =i ATTENDED THE NINTH ANNUAL RESEARCH SYMPOSIUM - LAND DISPOSAL incineration and T r e a t m e n t " of h a z a r d o u s waste in Cincinnati DURING THE FIRST WEEK OF MAY. THE TECHNICAL MEETING WAS PRESENTED BY THE EPA TO HIGHLIGHT THE RESEARCH AND DEVELOPMENT WORK COMPLETED BY EPA STAFF AND EPA CONTRACTORS. DISCUSSION OF The t e c h n i c a l r e s Ou r c E"Do c u m En t s c o m p l e t e d " to d a t e f o r h a z a r d o u s WASTE DISPOSAL WAS A HIGHLIGHT OF THE CONFERENCE. THESE DOCUMENTS WILL BE ORDERED TO ADD TO THE ENVIRONMENTAL ENGINEERING GROUPS DATA BASE FOR A BETTER UNDERSTANDING OF THE DOCUMENT RESOURCES TO BE USED BY THE PERMIT WRITERS AND FACILITY DESIGN REVIEWERS. THE PROCEEDINGS OF H E CONFERENCE RELATED TO LAND DISPOSAL ARE TO BE "ISSUED" IN" THE NEXT 90 DAYS. ATTENDED "DR. JAMES TIEDJE'S TALK ON THE MECHANISM OF 3I0DEGREDATI0N. THE SEMINAR WAS ORGANIZED BY BILL GLEDHILL TO HIGHLIGHT WORK BY DR. TIEDJE AND HIS GRADUATE STUDENTS AT THE UNIVERSITY OF MICHIGAN. THE TALK DEALT WITH THE MECHANISMS FOR TREATMENT OF SPECIFIC CHEMICALS AND HAS POTENTIAL APPLICATION TO THE EFFORTS ON QLYPHOSATE DESTRUCTION. OR OTHER SPECIFIC CHEMICALS SUCH AS THE PRIORITY POLLUTANTS. CLA-9=IU.-SEOUL AiaaX-SBPQbSE CONTINUED EFFORT" "ON TCDD QUESTIONS FOR EPS IN RESPONSE.TO" REQUEST BY JIM WILSON. RESULl_S_ OF FIELD TESTS MATCH PREDICTIONS FOR THE LONG TE RM FATE OF TCDO BASED ON SAMPLES TAKEN BY EPS FROM" A CONTAMINATED SITE IN TIMES 3EACH, ___AS A RESULT OF THIS EFFORT MONSANTO EPS PERSONNEL VISITED DOW CHEMICAL TO DISCUSS THE AVAILABILITY OF PHYSICAL PROPERTY DATA ON THE DIOXINS. DOW OFFICIALS INDICATED THAT THEY HAD NOT DEVELOPED ANY BASIC PHYSICAL PROPERTY DATA OR EVALUATED THE QUESTION OF TCDD FATE. MONSANTO HAS ELECTED TO HAVE PHYSICAL PROPERTY DATA MEASURED FOR TCDD TO VERIFY SOME OF THE VALUES I FSTIMATcD EARLIER THIS YEAR THIS DATA DEVELOPMENT WILL BE USED IN THE SUPPORT DR. ROUSH Tn"""HiS ACTIVITIES 'ON THE MISSOURI TCDD BLUE RIBBON TECHNICAL COMMITTEE. THE DATA MAY ALSO BE OF VALUE IN ACTIONS INVOLVING MONSANTO PLANTS WHICH HAVE OR ARE PROCESSING CHLORINATED PHENOLIC COMPOUNDS. ----------------G 4 3 5 S 3 ----------------- VISITED WITH NIOSH CONTROL TECHNOLOGY PERSONNEL TO PASS ON COMMENTS RELATED TO THEIR LATEST PPOPOSAL FOR OEALIn G WITH EXPOSURE CONTROL PRACTICES IN THE CHEMICAL INDUSTRY. Th E TALKS WENT VERY WELL AND THE COMMENTS WILL BE USED IN_THE_ AGENCY'S EFFORTS TO EFFECT TECHNOLOGY TRANSFER OF CONTROL PRACTICES VIA A DOCUMENT EQUIVALENT TO THE CED WORKPLACE EXPOSURE CONTROL MANUAL. WITH ANY LUCK THE AGENCY WILL DOCUMENT NEW DATA WHICH CAN BE USED IN THE PREPARATION OF ADDIT_IONAL__GUI_DELINES_FOR_ THE CED YELLOW BOOK. THE MEETING WITH THE AGENCY PERSONNEL* PLUS A TELEPHONE DISCUSSION HELD EARLIER IN THE MONTH. ALSO INVOLVED A REQUEST FOR SUPPORT FOR THE " TECHNICAL "PROGRAM AND PRACTICAL INPUT TO OFFSET COMMENTS FROM UPER _ MANAGEMENT NIOSH OFFICIALS WHICH CALLED. FOR MORE INVOLVED FIELD TESTS. " COMMENTS WERE GIVEN ON THE SUGGESTIONS BY THE NIOSH MANAGEMENT AND THE INFORMATION WAS PASSED TO TOM EVANS OF EPS. CMA CONTROL TECHNOLOGY TASK GROUP ACTIVITIES WILL FOCUS ON INVOLVEMENT WITH NIOSH MANAGEMENT TO AVOID MORE COMPLEX TESTING DURING NIOSH PLANT VISITS. ASSISTED LEO PARADIS ON THE PREPARATION OF COMMENTS ON THE PROPOSED CTG FOR EMISSION CONTROLS FOR THE POLYMER RESINS AND SYNTHETIC FIBERS INDUSTRIES. THE COMMENTS WERE USED FOR INPUT TO THE CMA TESTIMONY AND WRITTEN INPUT AND IN COMMENTS TO BE SUBMITTED BY LEO FOR"MONSANTO. 2. COtiSULIli^ A_9=S '" " NO FURTHER RECEIVED. ACT ION-" PLANNED SUBJECT TO PROTECTIVE ORDER, .*_ mLlECAllEiE-IQIaLA UN11L THE STATE RESPONSE I~S" CLA-3=2111-EN^1B Uni LAttUlI-Sl.-L&LLlS. _HQ. 90* OF MY ACTIVITIES IN APRIL CENTERED ON ENVI RO-CH_E_M CONSULTING EFFORTS ON THE KEOKUK ARBITRATION CASE. COMPLETED A REVIEW OF THE DOCUMENTS USED BY THE CITY OF KEOKUK IN SUPPORT OF THEIR LEGAL ACTION. THE COMMENTS WERE GIVEN TO BOTH IN-HOUSE AND EX-MONSANTO LAWYERS DURING AN ALL DAY TRAINING SESSION HELD AT THE EX-MONSANTO LEGAL STAFF OFFICES IN DES MOINES. "THE " TRAINING "SESSION INCLUDED A SESSION ON THE TECHNOLOGY OF WASTEWATER TREATMENT TO FAMILIARIZE THE LAWYERS WITH "THE-- [LANGUAGES "THE"FIELD AND THE SPECIFICS OF"" THE KEOKUK w a s t e w a t e r TREATMENT PLANT. A MEETING WAS HELD WITH SVERDRUP AND PARCEL PERSONNEL TO DISCUSS THE QUALIFICATIONS AND CANDIDATES FOR TECHNICAL CONSULTANTS TO REVIEW THE TREATMENT PLANT DESIGN AND TO DOCUMENT THE RESPONSIBILITIES FOR THE PRESENT" TREATMENT PLANT DESIGN PROBLEMS. ACTIVITIES In may will CENTER ON FURTHER DEFINITION OF THE QUESTIONS RAISED" DURING THE MEETING WITH THE LAWYERS IN DES MOINES. THE COMPLETION OF A REVIEW OF THE ENVIRO-CHEM FILES FOR "APPROPRIATE SUPPORT DOCUMENTS AND VERIFICATION OF PAST TECHNICAL ANALYSIS ARE TO BE COMPLETED FOLLOWING A VISIT TO THE KEOKUK TREATMENT PLANT. NO FIRM SCHEDULE IS SET" FOR THE PLANT VISIT ALTHOUGH THE ARBITRATION CASE IS TO BEGIN SOMETIME NEAR MID-JUNE. "fc PAGE 3 c e lls s i s a l- 5JJPEBau c-L a& aiailies a EFFORTS TO ESTIMATE THE MAXIMUM AND MINIMUM OPERATING TEMPERATURE OF THE LULING WASTEWATER TREATMENT BASIN WERE "c o m p l e t e d D r i n g e a r l y "m a y ." the 'e s t i m a t e s s h o w th e a c c u r a c y of THE ESTIMATING__PROCEDURE_BASED_ ON___A_ COMPARISON TO ACTUAL OPERATING CONDITIONS FOR THE" MONTH OF APRIL WITH ESTIMATES FOR JULY AND DECEMBER REPRESENTING THE WARMEST AND COLDEST MONTHS. THE RESULTS WERE PREPARED AND DOCUMENTED AT MY DIRECTION BY ERIC 3R-IMEff. _______ CEA W-915B IFENTON CONSULTING^RESINS. TRENTON. Ml . FORWARDED A PROPOSAL FOR RESEARCH ON THE USE OF ANAEROBIC PRETREATMENT TO JEFF WHITING OF THE RESINS OPERATING UNIT. THE $15.000 PROPOSAL WAS PREPARED BY BILL ELWOOD BASED ON SOME WORK BY THE FIRM THAT COMPLETED THE FAYETTEVILLE ANAEROBIC TEST WORK. THE PLANT IS VERY INTERESTED IN THIS TECHNOLOGY AND HAS REQUESTED ADDITIONAL ECONOMIC DATA TO PREPARE A REQUESt FOR RESEARCH EFFORT. THE OPERATING p e r s o n n e l h a v e a p p r o v e d the test WORK but the TECHNICAL STAFF NEEDS THE ECONOMICS TO SHOW THE POTENTIAL FOR SAVING ON THE PROJECT IF SUCCESSFUL.____BILL ELWOOD IS HAVING THE_ DATA PREPARED FOR THE PLANT BY THE CONSULTANT. TO COMPLETE AN ENVIRONMENTAL IMPACT ANALYSIS RELATED TO A POTENTIAL NEW PRODUCT FOR THE TRENTON PLANT IN MAY. _________ ___ __ .V..__________________________________ ..... ___ V.J ILLINOIS HAS COMPLETED ITS EFFORTS ON THE FJGITIVE FMISSION REGULATIONS AND HAS FORWARDED A COPY OF THE ECONOMICS FOR REVIEW TO THE PLANT. A MEETING IS TO BE HELD IN MAY WITH THE PLANT PERSONNEL AND THE EPS STAFF AND LAWYERS TO IDENTIFY THE KEY POINTS TO BE FORWARDED TO THE ILLINOIS EPA PRIOR TO THE JUNE HEARINGS ON THIS REGULATION. THE" EXPERIENCES OF THE W&K STAFF ARE TO BE PRESENTED AT THE ______ JUNE ENVIRONMENTAL WORKSHOP BY ME. _^J^aiit&-0BMALDEriD^!!liS5a^siP *_LULI*. -L NO ACTION ON THIS PROJECT THIS. MONTH. ___ _________ GON SUBJECT TO PROTECTIVE OHUtR. 018584 3 . HIiCk:LAblLLiS. ATTENDFD A MEETING WITH THE FELLOW SYMPOSIUM PROGRAM COMMITTEE TO GET APPROVAL ON THE PROGRAM FOR THE SECTION OF THE PROGRAM WHICH I AM RESPONSIBLE. I ALSO " MET WITH BOB REASS OF CORPORATE TRAINING__AND_BOB__LAFTON J O __DISCUSS THE DETAILS OF THEIR PRESENTATION AT THE FELLOW SYMPOSIUM. PROVIDED DATA TO RICK BELL ON THE TOTAL DISSOLVED SOLIDS (TDS) IMPACT ON WASTEWATER TREATMENT PROCESSES FOR INPUT TO ED JAMRO OF THE DELEWARE "RIVER" PLANT FOR USE DURING PERMIT NEGOTIATIONS. CONTINUED JcTPRV IDE'`DOCUMENTS ' FOR BRENDA DAN IL10 OF THE CHOCOLATE BAYOU PLANT TO USE IN THE NEGOTIATIONS OF THE SORBIC AIR EMISSION PERMIT. THE STATE OFFICIALS REVIEWING THE PERMIT CONTINUE TO QUESTION THE INPUT ON FUGITIVE EMISSIONS USED BY THE PLANT IN THE PERMIf APPLTION. ANSWERED QESTION~BY~'GARY~JOHNSON OF MF I ON FUGITIVE EMISSIONS FOR USE IN THE ESTIMATE OF LOSSES FOP THE PROPOSED ACY UNIT AT CHOCOLATE BAYOU. PROVIDED INPUT TO RICH BALTZ OF NITRO ON SLUDGE HANDLING TECHNOLOGY FOR EVALUATION OF ALTERNATE DISPOSAL ROUTES._________ _ ARRANGED COLLECTION OF SAMPLES FOR DON KUO IN HIS EFFORTS TO ISOLATE A BACTERIA CAPABLE OF TREATING NT A WASTES AND WASTES FROM AN ACRYLONITRILE PLANT. THE CHOCOLATE BAYOU PERSONNEL ARE TO COLLECT THE SAMPLES OF SOLIDS FROM THE SEWER SYSTEM FOR DR. KUO* COMPLETED MARCH MONTHLY" REPORT THIS MONTH. "THIS WILL BE THE LAST REPORT PREPARED FOR GLENN SMITH BASED ON THE CED REORGANIZATION WHICH NOW HAS ME REPORTING TO WALT SCRUGGS. euajEa toPR0TErT,;,-_ *9 September 25* 1980 LlS:L i t t le As Mayor of the Town of Bancroft I frequently talk with W. StuartsCalwell, the Town's Attorney. This afternoon in a conversation with.him* he asked me how long I had been with Monsanto, and how long a member of supervision. It was when he began asking specific questions about 2,4,5-T, paraamino biphenyl, and Sopanox, that I became suspicious; and asked him if I was being "pumped".for information that may be used against my employer. He iaughed and said he was "just curious". I told him that I felt his interest some what beyond the bounds of normal, curiousity, and I resented being put in the position of a witness, even if only in an incidental conversation. Mr. Calwell asked specifically about the dioxin, thaf^; ^ shows up in miniscule amounts in 2,4,5-T. I told him^thatfi-fe is a dangerous substance, but its level could be kept in tdl'er*able bounds with sufficient process control. The Seveso iilci^ dent discharged a dioxin-rich substance apparently caused by a loss of temperature control. .The unusual incidents are the ones that, people remember. I also told him that there seems to me to be an element of individual^ susceptibility in connec tion to contact with this dioxin. Some people who have worked in the manufacture of 2,4,5-T are badly affected while others are not. This product was discontinued by Monsanto some time ago. I told Mr. Calwell1that-1 was involved in the analysis of this product, and that one of the procedures in the labora tory involved concentration of the dioxin to a level where it could be detected. I seen to have suffered no ill effects from it, and while this is no proof that it is harmless, should in dicate that..personal awareness of hazards connected with any chemical substance goes far in preventing injury. Regarding PAB, I did not work at the Nitro plant when it was manufactured. I do know that Monsanto ceased produc tion immediately there was an awareness of the effects of it. People who contracted the problems caused by PAB are not for gotten. It was not known beforehand what the substance could do to a person, but once known I feel Monsanto acted responsibly. He asked me why people who worked in Sopanox manufacture were provided with lemonade. Was it to flugh the kidneys? I told him that I didn't know. The stuff caused violent sneezing. In any case, this is a product that hasmft been made at Nitro for many years. CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER / C14888 Mr. Calweil was told that if he wanted any information he should, contact the Nitro Plant Manager's office or Monsanto Headquarters in St. Louis. He would not tell me why he was asking^ the questions, but it is probable that an employee or. former! employee has retained Mr. Calweil for some action against the Company. Gilbert D. Bayless Maintenance F.L.S. SUBJECT TO PROTECTIVE ORDER. J Cl4889 9999*0 rrS si/lft- _pr*V/\ w-o lr>^rr 8 ^) *p *v y+rfi