Document aJ438vb8QrorDBgV0X6Op2MKB

April 7, 1976 FILE AS KAREL 1 handled a call today from a Bob Knarr, OSHA, Cleveland, Ohio, who wanted to know the acute toxicity ot ASKARLL. 1 told him it was a generic term for a product containing some chlorinated aromatics. Apparently an outside trans former anut down at True-Tomper and the electricians aseigned would not go near the unit because of alleged toxicity of the fluid. I told him the products, in general, poseessed a low order of toxicity and suggested proper handling precautions. 1 suggested that the fluid be cap tured rather than drained onto the ground and sent back to the manufacturer for disposal. Knarr was also made aware of possible thermal burns which could occur if the fluid was not allowed to cool prior to handling. Fred.A. Johannsen alw HONS 05B193 t Of PCB ppms from GE and a SNAFU from EPA and DEC ichard and Ilia Ferris first heard the Rnews on the radio when they were getting up on August 8th. The Ferrises run the Croton Butt and Tackle Shop in Crolon-on-Hudson, New York, and as Kiclxird says, "The news was a big shock. The first thing thul hit me wns what it would do to our business. But then I gave it some thought--I had believed the Hudson wits coming along cleaner--and it just seemed as though someone had busted the balloon for everybody. It was heartbreaking having to Util the people who came in." The heartbreak along the Hudson was caused by an announcement from Ogden K. Keid, commissioner of the New York Department of Environmental Conser vation. Keid was quoted by Richard Severn in The New York Times, warning the public not to eat striped buss from the river or salmon from Lake Ontario. Prompted by a report received from the U S. Environmental Protection Agency. Keid said that the striped bass had more than 5 parts per million of PCBs in their flesh, the federal Food and Drug Admin istration tolerance limit for fish. PCBs, or polychlorinated biphenyls, are heat-resistant compounds widely used by industries throughout the world. They are tough chemical cousins of DDT, and they arc toxic to a wide range of life, including humans, where they have caused stillbirths in women. - Fish apparently ingest and store PCBs by taking in contaminated bottom sedi ments. eating lesser organisms, or simply hv swimming through water containing PCBs. Some indication' of the threat PCBs pose may be had from an answer given by Dr. James H. W right, a chemical engineer with Westinghouse Electric Corporation, who testified at an En vironmental Protection Agency hearing on proposed toxic pollutant effluent standards in May 1974. Asked by EPA I HONS 058194 attorney Alan Eckert, "When you look these steps to prevent the discharge of PCBs, did you attempt to flush out or clean sewers and drains contaminated with PCBs from old operations?" Wright replied, "I would he the most frightened man in the world to recommend the flushing out of old lines and old drains." Until Reid's announcement, it was generally assumed that PCBs escaped into the biosphere by chance and not deliberate release. To Reid's dismay, he learned that two General Electric Com pany plants at Port Edward and Hudson Fails on the upper Hudson, which man ufacture capacitors, had been releasing, by the company's calculations, the in credible amount of 30 pounds of PCBs per day into the river. Company sam pling records revealed the plants may have dumped 90 pounds of PCBs in a single day. The discharge from (he Fort Edward plant began in 1942 and from Hudson Falls in 1931, Reid was further dismayed to learn that his very own department had known of the PCB con tamination for several years but had said nothing to the public. Ever since 1965, when New York voters overwhelmingly approved an un precedented SI billion "pure waters" bond issue, state officials have been blowing trumpets about progress against pollution. But not a word was said about PCBs. According to GE records, the New York Department of Health gave the two plants a water quality certification in 1971, and in 1973 the chief of the en forcement section ofthe Division of Pure Waters in the Department of Environ mental Conservation did the same. Bureaucrats in the Environmental Protection Agency have not exactly cov ered themselves with glory, either. For more than a year, EPA scientists and bureaucrats had known that General Electric was polluting the Hudson with PCBs, but EPA policy-makers stalled until they Anally passed the buck to Reid. A few persons tried to take effective action but they were thwarted. In a memo dated May 31,1974, Sandra P. Kunsberg, an attorney in the Water Enforcement Branch of the EPA Region 11 office in Those ubiquitous PCBs The range of PCB uses is so broad that suiating tapes; in protection lacquers; in hurdly anyone can escape some con making plastic bottles; and in epoxy tact with them. As Karl E. Bremer of the resins for protective coating of metals. Environmental Protection Agency Rc- As a widely used additive in sealants-- vion V oflice in Chicago listed them last for caulking compounds and putty, for July for the Lake Michigun Toxic Sub concrete and asphalt, as well as in fire stances Committee, the uses-past and proofing sealants for floors, doors, ceil present--of polychlorinated biphenyls ings. and partitions. include: . In the printing industry, in the making In transformers and power capacitors; of'carbonless" carbon papers; as a coat as hydraulic fluids: as a diffusion pump ing for papers used in thermographic oil; in heat trunsfer applications; as plas duplicating machines; as an additive in ticizers; as adhesives in the manufacture xerographic transfer process (in Xerox of hrukc linings clutch faces, and grind (oner); and as a plasticizer for printing ing wheels; in making safety and acous plates and flexographic plates. tical glass; and as a laminate of ceramics PCBs also are a byproduct of paper and metals. recycling, and have been identified in In making washable wall coverings hardwood and softwood pulps. They arc and upholstering materials; in adhesives found in toilet soaps, barrier creams, in for envelopes and tapes: in coatings for hydrated lime used to manufacture glass, ironing board covers; as a dclustering in water treatment chemicals, in primer agent for rayons; as a flame-proofer for paints, coloring compounds, dcgreascTs, synthetic yarns; in waterproofing of in additives to zinc alloys, and in waxes canvas; as additives in paints and var used in the tool and die-casting process. nishes; in film casting solutions; in in- -ROBERT H. BOYLE New York City wrote to Dr. Richard Spears, chief of the Surveillance and Analysis Division: "Following the Jtoxic pollutant ef fluent standards} hearings [at which GE admitted dumping PCIfs). in a memo randum from Alan Ltkert to Meyer Scolnick, the Office of Enforcement and General Counsel in New York recom mended that this office undertake a care ful investigation of PCB discharges from the Foit Edward and Hudson Falls facil ities to determine whether or not there exists a health hazard within the meaning of Section 504 of the FWPCA [Federal Water Pollution Control Aci|." This provision authorizes the EPA administrator to sue to restrain persons whose pollution of waters causes "sub stantial endangermem to the health of persons or to the welfare of persons, where such endangerment is to the liveli hood of such persons ..." The recommended investigation was conducted in August 1974 by Dr. Royal J. Nadeau and Robert P. Davis of the Region 11 EPA laboratory, and they reported, based on GE figures, that the Hudson Falls plant was discharging up to 17.6 pounds ofPCBs per day and the Fori Edward plant up to 30 pounds per day. Minnows collected below the Gb dis charges averaged 78 parts per million of PCBs, while a rock bass contained 350 ppm of PCBs, prompting Nadeau and Davis to write: "The PCB level in the rock bass is greater than the maximum level docu mented for fish taken from any industrial river of the United States... This repre sents a new record for PCB contamina tion of freshwater fish." They also noted that "certain areas, particularly down stream from Station 4, are fished pri marily by the youngsters of Fort Edward. Ingestion of these fish by the populace would certainly lead to contamination of specific tissues in their bodies as docu mented by previous investigators men tioned in the introductory section of this report." Effective action was not forthcoming. Instead, last March the EPA Region II office stayed lenient abatement plans for the two plants after General Electric objcclcd and demanded an adjudicatory hearing to challenge PCB limitations. On July 7th of this year. Dr. Gilman i>. Veith of EPA's National Water Quality Laboratory in Duluth, Minnesota, wrote a "review" of the Nadcau-Davis inves- HONS 058195 i:h ligation which was passed on lo EPA in New York City and eventually to Reid. HThis field investigation has revealed the largest source of PCBs into the aquatic environment that I know of," Veith wrote. "It is my opinion that this report has been written in a conservative man ner and does not by itself adequately describe the significance of the General Electric discharge into the Hudson River ... The river for many miles downstream from the General Electric discharge could be contaminated with PCBs at levels one hundred times over the 10 ppt (purls per trillion] guideline set forth by EPA in 1972 und a thousand times higher than the recommended water quality criteria" of 1 part per trillion. Even after Reid made public his warn ing. Environmental Protection Agency bureaucrats in New York City were less than helpful. When John Hnrris-Cronin of the Hudson River Sloop Restoration Inc. requested in person a copy of the Nndeau-Davis investigation, Richard Wye, regional chief of the Water En forcement Branch of EPA, told Harris- Cronitt he would have to submit his request in writing. Aware of EPA run around techniques. Harm-Cronin had brought stationery, and he immediately wrote out the request. Flye looked at the letter and then told Harm-Cronin that under the Freedom of Information Act "we have ten days to decide whether or not to honor your request, and the lactic wc'rc going to employ with you is to use them all." Given such tactics, it is no wonder that in (he Hudson Valley the joke is that EPA really stands for "Everyone's Polluting Again." , Bolyrhlorlnited biphenyls have been W manufactured in the United Slates I by one firm, Monsanto Industrial Chem icals Company of St. Louis. The com pany began production in 1929, and although it has played cozy with its list of customers and production figures, esti- ,, males are that Monsanto produced 400,000 tons of PCBs between 1948 and 1973. It is not unusual to ship PCBs by rail by the tank-carful. Monsanto sells PCBs under the name of Aroclor. (In a bizarre touch, government scientific publications dealing with the toxicity of PCBs begin with the footnote: "Aroclor is a registered trademark, Monsanto Company, St. Louis, Mo. Mention of commercial products or trade names does not consti tute endorsement by the Environmental Protection Agency") Monsanto makes Aroclor 1016, 1221, 1232, 1242, 1248, 1234, 1260, 1262, and 1268. The last two digits indicate the percentage of chlorine in the different compounds, except for Aroclor 1016, which actually contains 41 percent chlo rine. PCBs also have been manufactured in Great Britain, France, Spain, Ger many, Italy, Czechoslovakia, the Soviet Union, and Japan. Like DDT, PCBs are chlorinated hydrocarbons. Unlike DDT, which degrades in fifteen years. PCBs, especially the more highly chlorinated formulations, are essentially unalterable by microbial or physical chemical reac tion. PCBs persist because enzymes are unable lo shear the bonding between the chlorine atom and the biphenyl structure. The only efficient way to destroy PCBs is to burn them in a special industrial incinerator generating a temperature of 2,400degrees Fahrenheit. Although PCBs have been in use for almost SO years, they baffled scientists measuring DDT resi dues. who reported finding "unknown but chlorine-containing compounds." In 1966 Dr. SOren Jensen in Sweden iden tified the compounds as PCBs. Unlike DDT, PCBs are not used as insecticides but have many industrial uses (see accompanying story). And just recently fish oil has been identified as a source of PCBs. It would be interesting to determine if menhaden is affected. In a report submitted this past summer to the Rockefeller Foundation. William L. Dovel of the Boyce Thompson Institute in Yonkers, New York, reported that "the Hudson estuarine system makes a major contribution to the menhaden industry of the Northeast. Larval and juvenile stages develop in the Hudson and move toward the sea, where they represent the most valuable commercial fish species taken along the North Atlantic coast. Menha den arc ground into protein meal and oil to form additives for poultry and cattle feed, margarine, paint, lubricants, resins, putty, caulking, linoleum, soap, fertiliz ers, ink, electrical cables, and antibiotics. The cost of poultry probably would be prohibitive were it not for the rapid growth attained by adding high-protem meal to chicken and turkey feed. Fish meai is a richer source of protein than HONS 058196 129 soybean meal, its most important com petitor. it contains amino acids not round in vegetable protein and a yet unknown growth factor which makes its use in feed formulas particularly desirable.'* In 1971, by the time PCBs were present in a wide variety of products, Monsanto announced it would restrict sales to socalled "closed cycle" systems in trans formers and capacitors. However, trans formers do leak. Moreover, Uniicd States companies in nonelectrical manufactur ing have been importing PCBs from abroad. Aside from deliberate release, PCBs get into the environment from (he disposal of industrial and municipal wastes, burning of refuse, and leaching from dumps. According to a 1973 paper by Dr. George Harvey ofthe Woods Hole Oceanographic Institution, "PCBs are found universally in the sewage of major cities, although the atmosphere is the major pathway of global transport. Re cently, 50,000 turkeys in Minnesota, 88,000 chickens in North Carolina, and many thousands of eggs from various localities were destroyed after they were found to contain very high concentra tions of PCBs... PCBs have been found in all organisms analyzed from the North and South Atlantic oceans, even in an imals living under 11,000 feet ofwater... Based on available data it seems safe to assume that PCBs are present in varying concentrations in every species of wild life on Earth." Parts of the Great Lakes region have been sorely hit. Starting in 1971, Michi gan health authorities, primarily con cerned about PCB levels, cautioned the public not to eat salmon or trout from Lake Michigan more than once a week. The Great Lakes stales restricted the use of DDT in 1970, and since then DDT levels have dropped 87 percent in Lake Michigan fish. By contrast, PCB levels have remained ominously high. On No vember 8, 1974, Martin J. Schreibcr, lieutenant governor of Wisconsin, wrote about PCBs to A. Gene Gazlay, then director of the Michigan Department of Natural Resources'. "There exists now a problem with contaminants in Lake Michigan that has the potentialofdestroying both sport and commercial Ashing m all the Great Lakes. This situation could turn any efforts to develop the lake as a future protein source into a futile and frustrat ing endeavor. "Evidence is accumulating that shows that one group of chemical contami nants, polychlorinated biphenyls, or PCBs, exist in dangerously high levels in Lake Michigan right now ... Because they are extremely fat soluble, and be cause they are extremely stable, they tend to bioaccumulale in the food chain with more success than other pollutants. In human beings, PCBs have caused skin disease, jaundice, and toxic damage to internal organs, especially the Liver. In test animals, PCBs have caused swelling of internal organs, internal bleeding, and drops in reproductive capacity." Schreiber went on to note that he had asked the Wisconsin Department of Nat ural Resources Board to intensify efforts on (he PCB problem, and he ended by writing: "Unilateral action by each state is needed because sources in the En vironmental Protection Agency feel (hat it will be three or four years before any federally imposed standards could go into effect. Wisconsin and the other Lake M ichigan stales cannot afford to wait that long." According to scientists at EPA's Na tional Water Quality Laboratory, all Lake Michigan trout and salmon greater than twelve inches in length exceed the FDA limit of5 ppm ofPCBs. Indeed, this past May FDA seized interstate ship ments of canned and frozen coho and chinook salmon from Lake Michigan. The PCB levels were 7.6 to 10.9 ppm in the canned coho and 6.2 to 9.2 ppm in the frozen fish. This past summer the Sport Fishing Institute informed members that about half of the early-returning mature Atlantic salmon in the Boyne River in Michigan had died: "Laboratory analy sis has resulted in a theory that PCBs may be the cause, in combination with other environmental stress." In Lake Superior, large lake trout generally contain more than 5 ppm of PCBs. Two-fifths of the Superior basin is (he lake itself, and the suspicion is that PCBs are entering the lake mainly from air, rain, and snow. By contrast, the sources of PCBs entering Lake Michigan are many and varied. A report by Karl E. Bremer of the EPA Region V office in Chicago noted that "cooling water from aluminum foundries in the Milwaukee area have been found to contain PCDs. The source of the PCBs has been iden tified as hydraulic fluids from die-cast machines. The survey is now being ex panded to include other foundries." In Wisconsin, wastepaper used in recycling is a source of PCBs in streams entering Lake Michigan, and on the other side of the lake, the paper industry wastes m ihe Kalamazoo River create a contamination problem. And last winter, the Wisconsin Department of Natural Resources found that snowmelt in five of seven locations in the state contained traces of PCBs as high as .24 parts per billion. In addition to fish, Bremer reported. "A serious situation exists with respect to populations of fish-eating birds in the Great Lakes area. Severe reproduction failure has been identified in herring gull colonies around Lake Ontario. There is a positive correlation between early em bryonic mortality and PCD contamina tion. The major effect on young birds is to produce symptoms of chick edema dis ease (with) high mortality. Michigan of ficials have observed unnaturally high mortalities of gulls in recent years from Saginaw Bay and Grand Traverse Day. Analysis of the liver and brain of a dead herring gull from Grand Traverse Bay in 1973 showed the presence of 2,600 ppm of Aroctor 1254." ontamination from PCBs is of con Ccern elsewhere, loo. For instance, this year the Food and Drug Administra tion scucd 20,000 pounds of carp from Lake Pepin, a stretch of the Mississippi River 70 miles downstream from Minneapolis-St. Paul. PCB levels were so high the FDA buried (he carp. Carp and channel catfish taken from the Ohio River also have excessive PCB levels. F.PA informed the West Virginia De partment of Natural Resources of this on July 26, 1974. in 1969. scientists at the Gulf Breeze Laboratory in Florida, now pari of EPA, detected PCBs in oysters in Escambia Bay. A Monsanto plant that makes syn thetic fibers had been releasing PCBs from its heat exchange or lubricant sys tem into the Escambia River Embar rassed Monsanto officials moved to cor rect (he situation, and ihe release has diminished by quantifiable amounts. Gulf Breeze scientists have done a number of studies on PCBs and, curiously, the fish found to have the highest residues was not a predator but the silversides (Mtnidia benlhnai, a spe cies that feeds mainly on plankton. It is worth noting that in 1969 the Escambia Bay shrimp fishery went to hell In 1968 landings totaled more than one million pounds; in 1969, 234,000 pounds; and in MONS 058197 ISO 1970 only 52,000 pounds. Southern California waters contain PCBs, too. According to David R. Young and Theadore C. I lecsen of (he Southern California CooMul Wutcr Research Proj ect: "In contrast to DDT compounds, PCBs are widely discharged from sub* marine outfalls along the southern Cali fornia coast... PCBs now constitute the major chlorinated hydrocarbon contam inant found in municipal wastewaters discharged to the Bight, amounting to approximately three and one-half times the input of DDT compounds." At the May 1974 UPA hearings on toxic pollutant effluent standards a General Electric witness testified not only about the PCB releases into the Hudson but elsewhere as well. A General Electric transformer plant in Rome, Georgia, was discharging PCBs into the Oostanaula River "on the order of one pound per day." The effect on the biota of the river was unknown because, ns the witness, Dr. Edward L. Simons, admitted, "We have made no measurements of biota for any facility of the General Electric Company." Dr. Simons also testified (hot the Gen eral Electric transformer plant in Pitts- Acid, Massachusetts, released PCBs into the Hcusatonic River. In the vicinity of the outfalls, according to "occasional samples" by General Electric, the river water contained between 1 and 3 parts per billion of PCBs, while the levels in the sediments ranged from 130 to 1,300 parts per million. At "a distance of something between one and six miles" downstream, PCBs were "not detectable" in the water, hut PCB levels in the sediments were 30 to 60 parts per million. Dr. Simons pointed out that the Pittsfleld plant was releasing an average of only 0.1 pound per day of PCBs into the Housalonic, with "occasional excursions as high as 0.8 pound per day." "To pul (hut 0.1 pound per day in a possibly more illustrative format," Dr. Simons said, "that would correspond to a small jigger ofwhiskey, about one ounce, so we are not talking about a major spill. This is a relatively small volume of liquid." Later, Dr. Simons testified that "a loss of something on the order of one ounce during the day's operations is, we think, a very creditable performance. 1 don't know of any other really heavy manufacturing operation which handles fluids in which that kind of level of control is displayed." ' For sheer screw-up, New York State takes Arst place. The September 29,1972, issue of Science carried a paper by Dr. Donald J. Lisk and Carl A. Bache of the Pesticide Residue Laboratory at Cornel) University and two other Cornell scien tists reporting that all lake trout tested from Cayuga Lake contained PCBs, and that 80 percent of those more than 22 inches in length had levels that exceeded S ppm. The highest level, 30.4 ppm, was found in a nine-year-old Ash. There was a "highly signiAcant" correlation between PCB concentrations and the age of the Ash. "The Ash were netted in October 1970," the paper noted. "Their ages were accurately known, because the Ash are annually stocked as yearlings and dis tinctly marked as to year class." No one in the state Department of Environmental Conservation bothered to call the Cor nell scientists about their Andings. In fact, the only call Bache remembers getting was from a chemical company represen tative (not Monsanto) who wondered where the PCBs were coming from. To strike a personal note, I am not surprised by the past inactivity of the New York Department of Environmen tal Conservation. In the 1960s it actively suppressed information and photo graphs dealing with huge Ash kills by Consolidated Edison Company's Indian Point No. 1 nuclear plant on the Hudson, and for several years the department officially treated the lower Hudson as nonlidal (but it is tidal) because that apparently suited the corporate conve nience of the power industry. Indeed, 1 was once dismissed from the stand at a DEC hearing on Consolidated Edison's proposed Storm King pumped-storage hydroelectric project because my sworn testimony that the lower Hudson was tidal was "hearsay." 1 have had personal experience with DEC on PCBs. The October 26, 1970, issue ofSports Illustratedcarried, my long article, "Poison Roams Our Coastal Seas," dealing with DDT, PCBs, and other contaminants in gamefish from the Atlantic, Gulf, and Pacific coasts. The analyses, paid for by Sports Illustrated, were conducted by the WARF Institute in Madison, Wisconsin. They revealed, among other things, lhat Hudson River striped bass had 11.4 ppm of PCBs in the eggs and 4.01 ppm in the flesh. (These levels were also reported in my article, "The Hudson River Lives," in the March 1971 issue of Audubon.) I hold a state scientific collector's li cense to seine fishes from the Hudson, and I am required to make an annual report. On February 17, 1971, | did so. and in my letter to Carl Parker, chief of the Bureau of Fish in (he Department of Environmental Conservation, I told him of Ihe DDT and PCB levels in the eggs. "These are grim figures," I wrote, "and i certainly think the state should warn fishermen not to cat striped bass eggs" I also told Parker that (he levels in the flesh were "not great reading" and I suggested he read the Sports Illustrated article. Parker's reply was derisive. For all this, documents obtained from DECbyJohnHarris-Croninand Hudson Riverkccper Tom Whyatt show that the stale began collecting Hudson River fish as early as July 1970, although PCB analyses were not performed until 1972. PCB levels in excess of 5 ppm were found in iargemouth and smallmouth bass, striped bass, northern pike, sturgeon, and white perch. One largemouih 14.7 inches long, taken at the mouth of Esopus Creek, had S3.8I ppm. In April 1973 DEC collected 22 striped buss from the Hudson River near the Tappan Zee Bridge. The Ash were analyzed in 1974, and PCB levels exceeded 3 ppm in 18 of 22 fish. The highest level was 49.63 ppm. Not a word was said to the public, in May 1975 six striped bass were taken from the Tappan Zee area and analyzed; four of six had excessive levels, the highest 37.80 in a six-pound striper. igh PCB levels in Hudson River Hstriped bass mean trouble else where. After spawningin the Hudson, Ihe bass disperse along the Atlantic coast at least as far south as New Jersey and at least as far north as the Merrimack River, 40 miles above Boston. It is impossible for a coastal fisherman to distinguish between a Hudson striper and bass that have migrated from Chesapeake Bay,, with its numerous spawning rivers. No serious PCB contamination has yet been discovered in the flesh of adult fish in the Chesapeake system, but in 1971 Stripers Unlimited had fuut large female striped bass taken in southern New England waters analyzed for l'CBs. The WARE Institute found the PCB levels were 13, 18, 37, and 46 ppm. No one knows the river of origin of these fish, which were caught in Narragansett Bay and off Nantucket. In New York State in the early 1970s, MGNS 058198 information of vital importance to the public concerning PCB levels in Lake Ontario coho and chinook salmon was suppressed. A* I was writing this article, a scientist who requested anonymity sent me copies of PC'S analyses performed on Luke Ontario salmon by the Rome Pol lution Laboratory of the Department of Environmental Conservation between December 23. 1971, and September 26. 1973. Seven chinook salmon collected in the fall of 1971 were analyzed. One chinook had 15.29 ppm of PCBs. and that was the lowest level of any chinook tested. Five of the fish had PCS levels ranging from 20.35 ppm to 27.23 ppm, and one salmon, a 6-pound, thirteenounce male, had 34.48 ppm. One scientist within DEC, Ward B. Stone; wildlife pathologist at the Delmar Wildlife Research Laboratory near Al bany, had warned administrators and superiors for several years that PCBs were a menace, liis warnings, Slone says, were "futile," and there were times he wondered if he were crazy and the rest of the department sane. "No one really cared." says Stone. In one blunt memo, he wrote: "I hope the department begins to take some of these toxic problems seriously ,.. because it is doubtful these problems can be put olf. In fact, they have already been put ofT far loo long." Stone was busy testing and accumu lating data. With Frederick D. Baker, Casimir F. Tumusoiiis, and Brian Bush, scientists in the state Department of I lealth, he worked on levels of PCBs and trace metals In waterfowl. Seven species of waterfowl were analyzed for PCBs, and in two of them-the greater scaup and whitc-wingcd scoter-PCBs were consistently found in tissues. The greater scaup is a favorite with duck hunters, who regard the breast meat as especially savory fare. To quote from the report: "Measurable levels of PCBs were found in most of the available tissues ofall specimens ofgreater scaup, a species that prefers large bodies of water (e g.. Lake Ontario, Long island Sound, Croat South Bay) during migration. The analytical data strongly suggest PCB contamination of these waters and the aquatic life on which the ducks feed. Since scaup are hunted for food and since 27 percent of the samples annlyred con tained a greater level than S micrograms per gram, which is the legal limit for poultry products, surveys of this species on a regular basis would be desirable. The level found approaches that which has been shown to cause chick deformi ties and embryonic death in domestic fowl... "While-winged scoters are very similar in their feeding and migratory habits to the greater scaup. They are primarily coustal during migration, although the specimens presented for analysis were collected from inland waters. AH the specimens had measurable levels of PCBs. (The highest was 20.4 ppm in the muscles.) Because of the similarity in feeding and habitat, data for the scoters and scaup may be combined to establish the presence of PCB contamination in the waters that are their environment." Two of six canvasback ducks collected from Canandaigua Lake in Ontario County had PCBs in their liver, muscle, and brain tissues. "These two birds may have been migrants from highly polluted areas," the report noted. One of the canvasbackshad levels of 16.1 ppm in the liver and 10.2 ppm in the brain. This same canvasback also hod lead levels of 12.6 ppm in the liver and brain tissues, and the duck is believed to have died from malnutrition. The occurrence of PCBs in canvashacks is noteworthy inasmuch as last February the National Wildlife Federa tion petitioned the U.S. Department of the Interior to review the status of the species because the "once abundant can vasback duck is low in numbers and distributed over a diminishing range of suitable breeding and wintering areas. The stock of avuilahle breeding pairs is even lower as a result of the most unbal anced sex-ratio of any species of North American duck. This remnant canvas back population is faced with the loss of wetland habitat and with other stresses with which it is not equipped to deal." Interestingly, according to the Slone report, "No Canada geese showed quan tifiable levels of PCB or trace metals, except for one with cadmium in muscle tissue and two with mercury in liver tissue. The migratory movement of Can ada geese over New York Stale and their feeding habits (they are primarily her bivorous) apparently preclude the ac cumulation of PCBs to any detectable degree." In other animals, Slone has detected 30.16 ppm of PCBs in the liver of a great blue heron from Albany County and 16.57 ppm in the brain of a great blue from Cayuga County. A dead herring gull from Oneida Lake had 21.49 ppm tn the muscle and 11.05 in the liver; an mter from Twitchell Lake in Herkimer County had 49.39 ppm in the brain; and a porpoise washed ashore at Wcsihampton Beach, Long Island, had 20.3 ppm in the liver. here is increasing concern about the Tsynergistic effects PCBs might have on animuls or that they might reduce resistance to disease. For instance, in 1970 Milton Friend and Daniel O. "You're a disgrace to the herd." MGNS 056199 J .12 Trainer reported in Science (hat mallard ducklings fed Arodor 1254 Tor ten days showed no apparent ill effects. The duck lings were then fed food without PCBs for five days and exposed to duck hepa titis virus. The mallards suffered signifi cantly higher mortality than did birds not fed PCBs. ' Among mammals, PCBs have had severe effects on the reproductive capac ity of mink, and in a paper to be pub lished in the Journal of the National Cancer Institute, Dr. Konate Kimbrough of (he Center Tor Disease Control of the U S. Public Health Service and a (cam of researchers found that female rats fed Arodor 1260 developed liver cancer. Very important research on primates has been done by Dr. James R. Allen and Deborah Barsolti of the University of Wisconsin Medical School. Allen and Barsolti fed two groups of rhesus mon keys PCBs in a laboratory experiment. One group got food containing 5 ppm of Arodor 1248, and the other group re ceived food with 2.5 ppm ofthe chemical. In two months, monkeys in both groups lost hair from their faces and necks and their skin took on a "sandpapci-like texture." Both groups came down with acne, although it took the 2.5 ppm group longer to develop it. After six months, both groups were bred to control mon keys that had not been fed PCBs. Six of the eight females in the 5 ppm group became pregnant. Four of the six ri- sorbed the fetus or aborted, one had a stillbirth, and one gave birih to a very underlined infant. In the 2.5 ppm group, all eight females became pregnant. Three resorbed the fetus, and the other five gave birth to undersized infants. And what of the human experience? In 1968 about 1,000 Japanese, nearly all on the southernmost large island of Kyu shu, were officially diagnosed as hav ing what is now called "Yusho" disease after they used rice oil that had been contaminated during processing with an estimated 1,000 to .1,000 ppm of PCBs, Estimates of the persons affected reached 15,000. Yusho symptoms include severe ocne-or what is now called ,*chloriicnc',-chccsclikc discharges from the eyes, skin darkening, hearing loss, and neurological disorders. A number of newborn infants had abnormal skin pigmentation as the result of transpla cental transmission of PCBs, and the ma jority of the fetuses born were smaller than the national standard. There were stillbirths, and according to a report by Japanese physicians, examination of one stillborn fetus showed abnormal skin and hair development. Little clinical work on humans has been done in this country, although the Environmental Protection Agency cal culates that half the population carry 1 to 3 ppm of PCBs in their fatty tissue. One would have thought General Electric might have done research on employes working around PCBs, but aside from transferring an employe suffering from chioracne to another operation General Electric has done nothing. Several ^conservation organizationsthe Natural Resources Defense Council, Hudson River Fishermen's Association, and Hudson River Sloop Restorationhave asked EPA Administrator Russell E. Train to take immediate action against General Electric under federal law to curtail the discharge of PCBs into the Hudson. In Congress, hearings on PCBs in fish have been scheduled by Repre sentative Robert L. Leggett, chairman of the Subcommittee on Fisheries and Wildlife Conservation and the Environ ment of the House Committee on Mer chant Marine and Fisheries-at the re quest of other congressmen. Representa tives John D. Dingell ofMichigan, Edwin B. Forsythe of New Jersey, Richard L. Ottinger of New York, and Gerry E. Studds of Massachusetts. The simplest solution to the PCB problem would be for Congress to ban the chemical, as Japan has done. Mean while. in New York Commissioner Reid has now advised the public not to eat any fish at all from the Hudson, and he reports PCBs have been found in fish from the Mohawk River and the St. Lawrence. Reid has charged that "by discharging the toxic and deleterious substance PCB for more than twenty years. Genera) Electric has done serious if not irreparable damage to the Hudson." In a complaint brought in September, the New York Department of Environ mental Conservation accused General Electric of violating stale water quality standards and the state Environmental Conservation Law, and a hearing was scheduled at which DEC was to seek an abatement order requiring the company to reduce its PCB release to two pounds a day by the end of this year and zero by September 30, 1976. DEC is also asking that civil penalties be assessed against General Electric, that the company "take steps to restore the Hudson and to elimi nate contamination ofthe river." and that it post a minimum compliance bond ofS2 million. And another investigation has been ordered by Reid. "There has been a failure of government here, and some failures within the department," the commissioner says. "1 think the public is entitled to know all the facts." --ROBERT H. BOYLE Know Audubon's regional fieldmen Periodically we publish a list of the National Audubon Society's regional representatives. Here is an updated roster of the fieldmen who serve in our nine regions and (he states for which each is responsible: Northeast: Richard C. Rhmdress, P.O. Box 151, Sicphcntown, New York 12168 (Connecticut. Maine, Massachusetts, New Hampshire, New York, Rhode Is land, Vermont). Mid-Atlantic: Richard J. Martyr. P.O. Box 4181, Harrisburg, Pennsylvania 17111 (Delaware, Maryland, New Jersey, Pennsylvania, Virginia. West Virginia). Southeast: W. Carlyle Blakency Jr., P.O. Box 28191. Atlanta, Georgia 30328 (Alabama, Florida, Georgia, Mississippi, North Carolina, South Carolina). North Midwest: Edward M. Brigham III, R.K. 4, Roving Hills, Red Wing, Minnesota 55066 (Iowa, Michigan, Min nesota, North Dakota, South Dakota, Wisconsin). Central Midwest: Myron J. Swenson, Mauckport. Indiana 47142 (Illinois, In diana, Kentucky, Ohio, Tennessee). Southwest: John L. Franson, 2507 Rogge Lane, Austin, Texas 78723 (Loui siana, New Mexico. Texas). West Central: Ronald Klaiaskc, 813 Juniper Drive, Manhattan, Kansas 66502 (Arkansas, Kansas, Missouri, Nebraska, Oklahoma). Rocky Mountain: Robert K. Turner. P.O. Box 3232, Boulder. Colorado 80303 (Arizona, Colorado, Idaho, Montana, Utah. Wyoming). Western: Paul M. Howard Jr.. 555 Audubon Place, Sacramento. California 95825 (Alaska, California. Hawaii, Ne vada, Oregon. Washington). HONS 056200 /.r.f