Document YrkrEvdbmYvJp3JKv4o9xONYN
R&S 029560
A^
' f-U '
A Division of The Society of The Plastics Industry, Inc. August 13, 1987
Roy T. Gottesman
Executive Director
TOs The VI Health, Safety and Environment Committee
RE: Plaquemine, Louisiana Newspaper Article on Vinyl Chloride Effects in Miscarriages
I attach a copy of a newspaper article which appeared in the Plaquemine, Louisiana newspaper on Thursday, August 6th, which has been sent to me by Mitch Beaird of Georgia Gulf. Separately, I have discussed this with Beverly Gholson, an attorney at Georgia Gulf who called me regarding informa
|tion that we had on this subject.
^he latest information that we have is contained in the chapter by John Barr in the Encyclopedia of PVC, second edition, pages 252-254, and largely indicates that there is no data which points unambiguously to a relationship between vinyl chloride exposure and reproductive outcome.
If your company has any later information regarding vinyl chloride and reproductive outcome, I would appreciate your sending it to my attention as soon as possible. We may want to consider developing a "white paper" on this subject for possible future use.
RTG/pmb cc: M.N. Scheck
Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299
lAYOO
rRY
VOLUME t, NO. 32 PLAQUEMINE, LA.
s
*%7ny/ chloride*s effect?
THURSDAY. AUGUST , I9S7
R&S 029561
inSt.
; ByKa&yYofo Associate News Editor
'*
An investigation which began ladies that knew, cadi other, nine
with questions from residents in St had miscarriages and one had a live
Gabriel has lead me down a compli birth.*Fontenot explained.
cated path from the Department of
; He said he had fold DHHR
environmental Ooafity, division of about - This, . ` and / continued
the -Environmental ' Protection saying,"Georgia Gulf and - BF.
Agency, "to the liiU library; in Goodrich have had numerous leaks
search., of die. answers they re arid released forough . the. years; of
quested. Unfortunately, my exper vinyl chloride.* :
tise isnot hi Chemical Engineering
V-.Dr.Rrir^^
.
or.sdentific analysts.' -.Therefore, it that she didnt have the manpower
is not my position to offer thc fol to initiate-an investigation as exten
lowing" information as a conclusive sive as this one,*t this time, bat that .
answer to .those 'questions 'bring she did however;1 have some of her
raised in `the community pf SL staff trying to compile birth records
GabricL The ihformation compiled and statistics from thfe SL 'Cabticl
hercin acthaDy k a continuation of .-area.':
V_ 'K. `
their original questions, lsx it posAfrthat the'ernhsions of Hazar-
" Wben"? first began tins mye- tigation I spoke with I^y paudet, a
' ^Rs Air Pollutants from thcchcml- pharmacist In StGabrieLShesup-
cal plants in the St. Gabriel area, could have,. in -some .way, .con
pfiedme with/names of .' some women who she knew had suffered
tributed' to thc pnscamages, end miscarriages and diffichit pregnan
other mescal nod health. related cies. She alsotold me ofthe group
problems that residents ofthe com .ofwomcninthis area, (he ten ladies
munitysuffer from?
.who were afi pregnant kt the .same.
It has both said that rising con- time, and nine had miscarriage*,,
cern in the St Gabriel area pver.the . that -Fontenot-had spoke of,. ^Sh' ` past few months in telatipn to the a.djdj.edj itht.o.u_gLh-.t,Lhiat. t.1h-e--se, ladies aJltl'-
allegedly "high rate of miscarriage sufferedthcfrfoiscamjj^m.'tlrc
and trill births, has prompted inves tigations to. be initiated in Various
same, six to :.rig?d monfo .'time period, between late 1984 and early
state agencies "and. with a con 1985. Gaudet went pn to .explain
glomeration . of. environmentalist foal the national average fortok-
groups.
; v
- Congressman Charles *Buddy*
cairied pregnancies is 85 fortvery 1000 Irve'bkths,- ^hc explained that",
Roemcr . contacted the Attorney it would take 'SL ' Gabriel 15 ,1/2 GencraTs office asking for an inves years to havclOOO Eve biiths, there
tigation after lm was made aware of fore St Gabriel exceeded the Nih.
the suspicions of some women in St. tional Averagc b just rixmonths.
Gabriel who hatisuffered mkcar-
. ,v The *yarammeen I spoke with
riages and still baths. - WHlic Fon labeled Vfoyi, Chloride, a - Trial '
tenot, of the Attorney GcncfaTs Of- .toxin*. .. One woman said, ..'Vinyl
#confirmed .that he had sent a r to Dr. Sandra Robinson, of 'Departmerft of Health ind
Chloride causes Spontaneous abpr" tion in pregnant women.* ! ;
Vinyl chloride is a huitun carcin
Human Rcsonrccs asking than to
investigate. 'Basically, hi 1984, outoflO
ogen, is labeled as an'EPA faazardotu waste hnd a 'priority to^ic
ifSa VWYLCHLOR1DE, pofoaA)
Tt-
---- .*.&* . ,(t\\ ''
fV L *
VINYL CHLORIDE+l.
' -.. >* fom^Bed from pace *A)
| :<:.-
Vf
pollutant. The compound ' is -usually
T to the ISU Library In
In search Of facts as to how
encountered as a cooled liquid, yet search of support for what these much of this tone chemical has ac
is actually a flammable gat at room 'women had told me.. In ,a book tually escaped to the atmosphere in
temperature. Vinly chtyride is a called "Mutation, Cancer, and Mat: recent years, 1 went to the main of
colorless gas and is basically odor* formation*, written by Ernest H.Y. fice' of DEQ m Baton Rouge. I was .
bj. Yet at it*s threshold of human letection has a pleasant .ethereal xlor, 'similar to that of gasoline
du and Waldcrico -M. Generoso, under.' the- subheading *ymyl
allowed to examine file! which con* tained information concerning the
umt es.'. -' % -
. . .
' 1 called npon Mr. Bill Davis of
)EQ, head of the LESHAP sur-
rillance, (Louisiana Emissions
Standards for Hazardous Air Pol*
chloride*, I found support for their amounts of vinyl chloride which had
tM7h*IWeYoITvry*f*.*' ***''/ *--t - '-.v.vikd-.i been released. Under the direction
'*'*`"21*:*;
-ii.
of. Bill Davis,T-was given files for
Georgia Gulfy Dow Chemical and
y *An Increasedfetalmortality,^u-as observed for the wives of-Workers
B. F.Goodrich.1
utants), this division of the ; who'had been exposed 'to the foot Some ofthe files were incomplete'
IPA/ DEQ is the office which pound, and other studies have indi- and. others sitnply listed it date that
ssesaes whether or not a particular -fated an-increased: risk -of . birth an emissionnccurredwithout list
mission of vinyl chloride was pre defects in children.ofparfntsrefid* ing the amount involved. Thecntire
entable. Once an emission is tsessed as' either preventable. or
t
ing in the vacinity ofvinyl chloride . 'production' pod,polymerization
year of .1984 of-the Georgia Gulf surveillance file was liowhere to be -
on-preventable they begin the pro- ; plants," the passage read-. . . found: 'Therefore, 'only limited
ess of determining if any action i
*-*., * - . information concerning that partic
toukj be taken against the viola-
[4
r
`V* , ' ' V . * * t
ular timeperiod was made available ,
#
_
>
>r. Once.the Environmental Qual- ! . Georgia Gulf, Dow Chemical to.me. ' r:,\-:
; '
y Act bas been violated, the DEQ : and 'BJ.; Goodrich use vinyl
yen' decides what action, if any, ! chloride in their production proces* touUAe taken against the plant. ; set. Dow produces the chemical it-
Davis was successful in obtain!^
some, information from-another source concerning thls-year.--
DW could riot' confirm the ? selfand sells vinyl to B. F. Goodrich
ateiment by the women I spoke i` by pipeline, and ships the chemical
ith concerning vinyl chloride ! by rail also. 'When shipped by m3,
ring a fetal toxin or causing spon- - the chemical is a Gqtud.under pres
neous abortion.'. in . pregnant omen, he could ;only tell me in galnd to the subject that the t)EQ'
sure. -
- .Georgia Gulf also produces
spectors, those .who go to -the vinyl chloride , and sells the. chemi-
ants to do annual inspections and : caL They also are a'polymerization
nodical inspections to determine i plant, producing Polyvinyl chloride
e preventability of a ` particular . from -the vinyl chloride monomer, .
fission, cannot be .women of ` or creating PVC from YCM.
Ildbearing age.:
-B. F. Goodrich, as mentioned
In search ofproofthat what these .before redeves its vinyl chloride
omen had told me was in fact cntiflcally tested andr proven
mewherc, I. called Dr. James reman, Iberville Parish Coroner,
from flow Chemical by-pipeline, and they produce PVC rcsin and some PVC compound. ` Their
reman also could not confirm polymerization plant produces the
s. He did, however, agree with ' ; granular type resin to be shipped
\vis saying that vinly chloride bas out ` for ' the creation Of such
:n -proven to .mfuse angiosar- ; products 'as pipe fitting, construc
na, cancer of the liver. Davis had tion .industry electrical fittings,
d me that this was discovered at. wrapping products, such as plastic F Goodrich plants in Kentucky^. ~wap. That part of tire PVC resin
made Into -compound is cold for
From the avaHabiesaourids, the approximate number''/.f total
r pounds of vinyl chloride released
from these three plants from 1981
until the bcgjning of 1987 added up to 153,097^9lbs. ;
. .Sources of. these releases
varied but most were safety , valve
releases, pumps nnd other ' mal-
.. functioning equipment-::..Hciwevcr,
evciytime a plant starts' up or shuts ' down 'ustiswally `lalgc Remissions ..
' occur, this is also true' of shutting
down the boilers for inspections
and othcr operations.* 6a some oc-
caisions of boiler -shut down, in
which the EPA had given their per mission to the plant to conduct the
shut down iully aware ihat'cheini-
cals would be released, a-very Urge
amount of hydrocarbons '-were
.emitted.
'js5-.
things such as plastic bottles. .
O'
R&S 029562
v ' ~18rt3jiig thb^own, tl>c iooam-
pidt Georgia Golf fifes revealed 96,15639 lbs -of .vbqrl chloride i^ksed,Dow Chemical repotted !^KL80 lbs, and B. F. Goodrich
totaled 4L6873Q fcf enured oyer
the past 51/2 years. .,
* The years of the most concern to ` those' tesidents in Si. Gabriel
involved in this issue are those of 1984 and l9g5; According'to those.' DEQ records available, ^Dow . Chemical's total emissions from 1984 and 1985 were 288.00 lbs.
From 1984 to .1985 BFGoodrich emitted 24,612*35 lbs. of vinyl chlo-".
ride according to DEQ records. ..Georgia'Gulf, between 1984and 1985 according to the incomplete
. records at DEQ, had a total of v 29,633.48 lbs. of VCM released io
the atmosphere.... Georgia Gulfs releases for.that,
time period included a 17,760 lb.. release .of1 vinyl chloride -qn November 13,1985. frotti their PVC plant and 9,142 lbs.'that same day from their VCM' plant. These - releases also included * 1,900.1b. emission on April 23, -.1985 from* thrir VCM plant!' ^F Goodrich's releases .'-during ' ' t^Btimc period included a 5,400lb.'.
, release ofvinyl chlorideon lantuuy'
: 19,1984 ; and a 3400 Hx discharge
!. oaJannaiy 29,l984. 'Onjone22, J
, ; 1984, they released 2JD00 lbsJL'of vinyl chloride to the atmosphere
*. and on August J 5,-1984 6.8 lbs. with . >f- a 7,905 lb; rtlcase;bn'August 24-of
thaV' year. 4h:1985^ -they 'emitted "'4*00 Ibs'. bf yCM.6ti'May 6: . ",
According to'the DEQ records, Dow's .total reported ^emissions from 1986 up to date total 45.50 lbs. (of VCM emitted to the atmosphere. *. However.-in 1983 Dow Chemical released 4,42531 lbs. of VCM to the atmosphere according to-the records. These emissions included a 300 lb.' release on December 4, 1983, 750 lbs, on April 15, and the same week on April 18, 3,080 lbs. were released from the plant.'
In 1981 and 1982 Dow released 10,495 lbs. according to the"files. These releases included an 8,925 ib.
eon October 22nH962 anda b. discharge on' August II,
7 B F Goodrich, which receives it's ! vinyl chloride from Dow Chemical
[- by pipeline, emitted 13,429.1b*. wf j . * VCM -to^the' atmosphere in
j I983J These emissions included-a
7,500 lb. release on October 18 of
J 1983 and :5,000;.lbs.von -December..
14. 1983.
^;
-:
; In the years 1980 and .1981, B F
Go6d rich released 11350 lbs. of
' vinyl chloride.to the atmosphere. in 1983 the U.S. filed suit against
; B F Goodrich in relation to it's vinyl
, chloride emissions.- The .company
had to. pay approximately. r S 100,000.00 to the state as a result
' of the^e copiplaints.:
,/
Georgia Gulfs emissions inI986
and part of .1987 total to 5,796 lbs.
of vinyl emitted.
: \ '
From 1980-1982 the company
released S2;597 Jbs.. according to
DEQ records which. went .only as
. far-back, as .1980. ^
'
. On .September .20,' 4985 a pro
posed concent .decree .in .United . States'vs. Georgia Pacific Corpora,. lion was bridged with. the United
* States District Court, Middle Dis trict of Louisiana.' The .complaint filed by the'U.S! alleged that'the Georgia Pacific Corporation vio-.. . iated the ' Clean Air Act and the Vinyl Chloride National Emissions
Standard for Hazardous Air Pollutants, by discharging vinyl chloride'
'from its ethylene dichloride/vinyl, chloride and - polyvinly chloride* facilities. Georgia Gulf now is the - owner Jaf the . plant -. and ' conse quently intervened in the action to . effectuate - the -injunctive relief sought by the U.S. under Concent
Decree. The 'Concent -Decree
required-the plant to adhere-to a -
Remedial Action Plan .and ensure -.
cdmpliancc.-'The company had to-
pay 5562,500.00 in civil penalties to '
.the U.S. and an additional penalty:
bf :*;J62300.00 to *the .State of
Louisiana. .
\
Vinly chloride is used as a'vinyl ' monomer in the manufacture of
f~x
*
5 `*T. V -potyrinfi chloride and other reiin*. . According to /Mutation.' Cancer,
end Malformation, by Ernest H.Y.
. Cbu and WaldericO'M. Generoso,
. over 90 percent of vinyl chloride
monomer is usfed in the production
of vinyl chloride homopolymer and
; copolymer'resins'Used, in the build ing " and" construction' 'industries.
' The compound is' ufed in the crea
tion of/such things 'as'plastics, vmr-
aubes^silk and paper coatings ami
.refrigerants.
/t ' X
" 'According to the "Handbook of
Toxic and. 'Hazardous Chemicals,
byMarshall Sittig, the hazards of
vinyl . chloride was ;~oHginally
believed to primarily., concern
-workers'employed itr fhe ponver--
i,
sion Tide
of Y^M to PVC, `rrioribmef' to
(vinyl chib-; vpolyvinyl
'
; chloride) who may.receive a partic-
'.' ularly high exposure of VCM iq
certain' operations,' or long term
I exposure to relatively low conceq-
> . Untibns of VCM-in the air at differ-
v cm -factory sites! Much -.larger
.populations are now-believed to be .
: potentially at risk, including: pro\ ducers of \CM, people living in the
i dose proximity to VCM or PVC
t producing industries, users ofVCM
I as propellant in aerosol sprays, per- .;
r 'sons in contact with resins, made ' from VCM, consumers offood and .
beverage products .containing
teachable amounts of unreacted
VCM from PYC packaged roate-.'
rials (plastics, etc.), and ingestion of
water containing unreacted.'VCM
. leached from PVC pipes. ^
In 1976 it-was.-estimated.dliat
almost one ihilljon-^persons .`jwbre,
associated - wjth manufa^nring
goods derived freqi'pyc.',
-This :saroe. publication < jmys.
"Jhdnerators rnayf>e anpdditjonal :
xource efxvinyl chloride f'misifons
since-: the -entrapped \monomer,
escapesfollowing incompletexptn-
bustion of PVC products
- According to the.'firial-rule* of
the. P.EQ Regulations and Proce-
- dtires `forUnauthorized >DiS7
charges, 'which became 'effective
November 19, 1985,'therepoTtable
quantity level for vinyl chloride is
one pound. This level is applicable
regardless of i the environmental
: medium, (land, air, water, ground-
J-ater) into which the pollutant is ischarged.-This is the limit- the . . DEQ hai'act for-tbe plants to Wpprt
^m eroiBion..;
*
-' "Accorfic ;W'(bc 'pemn'tslfek i ; Ako fopad in Chem^SWizards
fipptMt Junits in air bitid in the ;. 'Vf*hr Woekplace."OverJiOewesof
Handbook, of. Toxic and Hazard- \ angiowroomaofilwk^Tha^hccn o^Chemioals* the federal stand-' Lreported omomg -VfayT-efasrkte
ftr exposure to vinyl chloride , polymeriestion workers fa the jLJrii-
fatsa limit oT I part per million over an 6 hour period, and a ceiling of5 ppm averaged over A period not
exceeding 12 minute*. * The chemical it absorbed both
through inhilation . arid 'akin
Absorption.
| . ted States and nine other nations. !. Because this tumor is extremely
j`. rare, the occurrence* of these cases under, similar occupational condi-
f. lions .'strongly suggests:! casual relationship to some phase of vinyl chloride production! Clinical fca-
According to the Handbook of { tunes of seven patients with the car
Toxit-and Hazardous jpbenticah-
cinoma varied from no signs or
medical-disorders associated with ` ..' symptoms * to weakness.: pleuritic
vinyl chloride include: acrobsteoly- k. pain..abdominal pain, weight loss,
*, Raynaud's phenomenon, and ockrodermatous skin changes. Chronic exposure may also cause
.gastrointestinal bleeding, and jlcpatospknomegaly; liver function abnormalities -were: present in all
hepatic damage. ` ~
: Vinyl chloride is regarded as a
hu'itta'n carcinogen Apd.a cause nfm npna renqia ofthe liver. Excess
cancer oftbeTungiind lymphatic
and nervous systenrihas also been
reported. Rxperimental evidence of
tumor Induction in a Variety' Of organs, including Uver. lung, brain
and kidneys, as well as nonmalig pant alterations such as fibrosis atid
connective -tissue deteribration
*e the mohisystem oncogenic. Stoxicologic.-effects of vinly
' :.
subjects hut without a consistent pattern. .In addition to.the malig! nant tumors,.four-cases.ofnonma TignanV hepatic disease charactcr. ized by portal fibrosis and porfal ' -hypertension have been attributed f 1 to .vinyl chloride exposure.'' ( . Continuing in. this publication, thcauthorJisfs symptoms and signs * of exposure as-'weakness pleuritic . f 'pain, abdomjnal -pain, anorexia,
( weight loss, gastrointestinal bleed! ing; hepatomegaly, .splenomegaly; i Raynaud's syndrome, lesions in the
oride. ;;
* , In agreement a. book, called.
'Chemical Hazards of-the Work place by Nick H. Proctor, PHD,
*
toxicologist and James P.,Hughs,
MD explains that there* is an
increased incidence of malignant
tumors, wcroosteolysis, Raynauds;
syndrome, aceroderma." thrombo
cytopenia,' ctrcutotoTy -disturban
ces, and impaired liver, function;
very high concentrations cause cen
tral nervous system depression, .
associated with the intake ofvar
ied amounts of vinyl chloride...
.'Radiologic'findings in patients
with acroosteolysis included .lytic
' lesions in the distal phalanges ofthe
hands, in the styloid processes of
the abut and. radius, And/in the
distal phalanges of the hands; cen tral nervous system depression.' ' "Numerous publications snp-ported this fact, that vinyl chloride exposure causes cancer of the liver i pr angiosarcoma, including a pasr. sage ju ;Mutations. : Cancer .and ' Malformation which listed a key event in which workers in numer* t* - qus countries showed.an increased incidence ofangiosarcoma. .
. Angiosarcoma is a very rare dis order qf the liver. I have also found eyidenre. that vinyl chloride expo sure'clearly produces gene muta tions and.primary DNA datnage. Reference was made to problems in " .-genetics and chromosomal defects ' in-relation to exposure..
sacroiliac joints.-Of 20 autoclaivc.
' DHHR has not yet compiled any
workers ; with exposure io vinyl < statistics that they would release on
chloride, 16 had thrombocytope
the birth rate in the St. GabriaJ
nia, seven bad splenomegaly, six
area, l am presently awaiting those '
had hepatomegaly, 14.had fibrosis j statistics along with statistics, on
of the liver capsuk arid four had sfafa of acroosteolysis in one study ii^Hs same publication: `
^The passages made reference to
incidences of cancers and other
| . related material. from an area
hospital. *
r.r.'vr i
.jr
numerous other disorders found in
workers-of VCM plants, including
-poe studywfekh iaw'2S cae ol
acroosteolysis, (degeneration Nof
tferminal phalanges)...
.
<>wronig. so -.tom .uaucogcT,
Director .of the State Center far
Health Statistics, fa 1982 IbcrriQc
.. Parish averaged slightly over the
state average for still births. From
the years 1983-1986 Iberville, was
slightly under the state average far
still bulbs, and fa .1986 none of
. those cases reported came from SL
j : Gabriel- ;
`
; According to those women 1 |. spoke with fa St Gabriel, instances [ of nmcaniagt and still births are _ higher than BaUenger** figures mdi-
i: cate. One of.these womtn said that ; - from 1983 to 1985 out of 17 prcgt nancies there were 15 .miscarriages | and one live birth..; .
i ' Several of. the women went on to
i have cliildreriJater but had to have-
' progesterone (a femaie hormooc)
supplements during their pregnan-
i ' cics following their.:miscarriages.
* None of there women had any
instances of.this type of complica-
* lions with childbearing in thelr fam-
ily histones.
. * * "
' If this is'ihdeed fact, we may find
'. reasoning-behind .these occurreni ces, and-'that reasoning may not
.. necessarily be those chemical emis
sions between theyears of 1983-85.
The evidence 1 mentioned briefly
before .conceiving /genetic.. and
- chromdsonal damage after expo
sure has opened up another field of
investigation. -The question of'the
*. .generation before this one's expo-
; sure hW''arises! Their parents.
many of which livied .'in the -area '
1'., years ago when limits set oh vinyl
chloride-, and othei .hydrocarbon
emissions were riot as strict as they
are now; could possibly be the ones
Who's intake was.too great.
This theory 1 will try to support
with more research, but to begin I
' quote from Mhtation, Cancer and
j Malformations, - 'Only dominant
| -mutations- and certain chrorao-
j -soma! defects- will have clinical
effects in the first generation. The
persistence of mutations depends
upon -the biologic Jitncss of the
phenotype.' If.Carriers of a given
mutation have no offspring because
, of kthality or infertility, the muta
tion will only persist for one genera
tion. Mutations ofthe hetcroZygolc
' type will, be-similar to that of nor
mals.' Such -mutations will persist
for tnany generations.*
,'jn addition to the information
presented in this article.l havedoc-
umented .evidence of releases of
! Chlorine and other hydrocarbons
; and their effects on the human body
--and the xnvfconmerit -which 1 will
present with further research at a
R&S 029564
im
-fks
ooo-S> Ck
OX
33 Co C/D
0 fo (O 01
CD
CJI
- v^'Vi1 -;- v-'<
vThe Department of Eoviriiniiien'
t1 Quity has in progress a fact
finding mfeaonto proride answers
to a posoMe fink between allega
tions of jniseafriagesaiid stillbirths
in the St Gabriel and the' environ*
mmt
Ji,' *
. The DBQ staff has pot together
a comprehensive plan to provide ns
with a variety of information which
we can share with DHHR/Martha
Madden, Secretary of DEQ said.
The Deportment of .Health and
Homan Resources, working in con-
jondioo with federal Centers for
Disease Control, is the lead agencey
V ;j;., r.;r,
jv V t
-w-A ;*.*>' viv.Kt.- vi'l '/an .ifae investigation L/i intothe
problem in StGabrieL ' The DEQ plan calls for informa
tion ror>i six (Efferent areas.':These include;'-. ' - ;.v" : .1. An inventory ot chemical products and byproducts produced
in the St Gabriel arca, r o t'.V;-' . -Z A study ofAccidental spills and
releases ovcr the past fiveyears, ; .
3.-;A retrospective ;*tudy. flf
.baseline data onair And-water
quality, <
a . j: r.>-
4.;. Grormdwater Vesting of
anocitoringwens,
5. Tests ofdrinking water sources
:and
-*..
6. Cooduct coQ and surface water
'sampling. ; -* ' '
i wcJute hceh -working on
.'answers to the : many :qucstions
-raised by `ibis' incident in -St
'Gabriel,* Madden concluded. *Bc
assured DEQ 1 is .well in -the
forefront far its doty to help DHHR
iofre this problem.* -v