Document wO8N2Gyb8D8wOVMaQReKpE7Q

Monsanto Monsanto Company 8 0 0 N. Lindberg h Boulevard St. Louis, M issouri 63167 Phone: (314) 6 9 4 - 1 0 0 0 June 22, 1983 DEPARTMENT OF MEDICINE & ENVIRONMENTAL HEALTH 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 /he Ends. CC J . A . Peters J. D. Wilson Jr., M.D. C04171 anto MONSANTO RESEARCH CORPORATION Dayton Laboratory 1515 Nicholas Road P. O. Box 8, Station B Dayton. Ohio 45407 Phone: (513) 268*3411 TWX 810*453-1681 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 v/ash concentrate from the so il extraction process. Another contractor (CH2M H ill) w ill excavate and,solvent extract the affected so il. Washing tests on only lOOg so il have shown 99% TCDD extraction but 3-4 ppb TCDD s t i l l remain with the so il -- this may s t i l l be excessive. Soil washing technology is rife with problems begging for technical solutions, e.g.: o Because efficiency of soil extraction depends on the surface area (so il) / mass (solvent) ratio, pulverization and drying (to remove 25% moisture) are necessary. Each of these pretreatment steps have a ir emissions problems. Moreover, the best solvents for dioxin are toluene, aromatic naphtha, and methylene chloride; toluene and methylene chloride are lik e ly to be classifie d as hazardous a ir pollutants by EPA in future rule-making. 6 Separation and concentration of the washed so il involves f ilt e r pressing and drying; these operations are equipment intensive and must include emission control. o Concentration of the wash solvent after extraction involves take-over d istilla tio n (energy intensive) for solvent recycle. Again, another process step which must have emission control. a subsidiary of Monsanto Company -To: George Roush, M.D. I ' 'l, 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. C ritical Fluid Systems, Inc. This firm is promoting the supercritical flu id extraction process, which is currently only a p ilot scale process. This means unproven technology and impossible-to-estimate costs. Consequently, they propose only a small-scale test program, which, even i f successful, does not guarantee their management and equipment a b ility 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 w ill 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. Arn\y research and application, e.g., their fa c ilit y at Tooele, Utah. They also had success with Kepone-contaminated so il incineration for ERA, but did not get the acclaim they fe lt 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. R ollins 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. Sim ilarly, 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 la n d fill with gravitational-force leachate collection and treatment system. They offer compelling points to consider: They correctly point out the decreased cost and time advantages for "ultimate" disposal by aboveground closure. i 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-D'Appolonia for Hooker Chemical in Montague, Michigan for hexachlorocyclopentadiene wastes. The resultant lan d fill would be a pyramid-shaped "monument" to man's past stupidity associated with contaminating these areas-- this can be viewed in a beneficial or derisive light (my comments). t Aboveground closure provides access and opportunity for in situ testing of biological degradation of dioxin in la n d fills. Aboveground closure can be designed to incorporate a bacterial seeding and nutrient circulating system to speed degradation. Separate c e lls 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 sitin g such a "monument" are immense, but any alternative will have furious sitin g 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 *3 ft * . II THE WALL STREET. JOURNAL, MONDAY. JUNE 20, 1983 Letters to the Editor / DioxiiiPanic Poisons Our Judgment Your penetrating editorial "Dioxin Hys pays the bills? We all do, of course. So it teria" (May 31) provided a sense of bal behooves those who make the judgments ance- and perspective that has been sadly' about risks and benefits and costs to make lacking in news coverage of Times Beach them carefully, unswayed by the hysteria and other areas. *V r- of the moment or the hyperbole on which it While I agree with your conclusion that thrives. *' 'i that is known suggests that "most of the . .John W. Ha n l e y scare -stories are exaggerated," I feel It -Chairman would have' been still more useful to point - " ~- Monsanto Co. oijt that the costs of this exaggeration and St. Louis * -~ , Qie resulting- hysteria have been stagger ing and are likely to haunt us for years. The high cost of hysteria to date is re "Dioxin Hysteria" justifies as well as flected, for example, in the Federal Gov sets an example of its title. There was se ernment's $33 million buyout of Times lective use of facts and scientific studies. A Beach, and in extravagant jury awards close reading of the.Nitro, West Virginia, such as the $58 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 tbe plaintiffs were not even-shown to have dence' Unking liver enlargement to expo suffered any ailments directly attributable . sure-can be found in this study and in the .to, the; spill. '.v report of the Council on Scientific Affairs ^ These examples are only a dismal p r e - " of the American Medical Association, also lude unless reason and `knowledge are referenced in the editorial. - Brought to bear on societal questions of Dioxin In the environment does not just tills kind. Hysteria and fear are poor sub go aw ay-m ost of the Missouri sites w e re : stitutes for rational decision-making on contaminated a doren. 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 w ay-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 - ' 1r " Dioxin Hysteria T H E ' WAL't. `STREET JOURNAL, TUESDAY, MAY 31. 1083 REVIEW & OUTLOOK- Hardly a day goes by without some impaired. No derangement of gesta frightening headline about dioxin-or tion, no fetal lethality and loss, no more precisely, 2,3,7,8-tetrachIorodi- gross malformations, no gross retar benzo-p-dioxin, one of 75 dioxins. This dation at term and no cytogenetic ab 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 risk reasons families near Love Canal of cancer as a result of their expo-, abandoned their homs. The federal sure, but studies of another dioxin ac government bought out the town o f cident more than 30 years ago suggest Times Beach, Mo., after th Center that this threat may be overblown. In for Disease Control recommended 1949, there was an explosion at an evacuation .at exposures above one other trichlorophenol plant, this one 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 Grange. 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 their worried about the stuff. High concen age, race and sex distribution. trations in the soil-30,000 times The Air Force has been conducting greater than the CDC evacuation stan an epidemiological study of the 1,200 dard-killed horses at Times Beach. "Ranch Hands" who were directly in In the laboratory, low doses in the volved in spraying Agent Orange in 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 such-as ' 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-caused 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 Protection sters. Since it would be unthinkable to Agency now bans the spraying of the conduct laboratory experiments on dioxin-contaminated herbicide, 2,4,5- people, researchers really don't know ; T,' on forests, pastures and rights of 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 study ease called chloracne, which tends to by the Environmental Health Sciences go away fairly rapidly. This is true' Center of Oregon State University even at fairly high exposure levels. concluded in 1979 that the `Tate of We have some real experience with spontaneous abortions in the study dioxin, resulting from major acci area does not appear to be related to dents, in particular the infamous ex the use of 2,4,5-T." plosion of a trichlorophenol plant in Seveso, Italy, in 1976. More than 700 people were evacuated from Seveso, and 181 contracted chloracne. So far, None of this means that dioxin is harmless. Certainly toxic chemicals should be carefully controlled, and ac 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 clear. 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.