#282: Radioactive Waste Problem Gets Worse

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #282
---April 22, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ========== RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
================== Original Source ==================

Hazardous waste incineration got another black eye during a recent Congressional hearing. It seems that for a decade--perhaps longer--hazardous waste incinerators have been illegally burning radioactive wastes shipped to them illegally by the federal Department of Energy (DOE), the agency responsible for managing the nation's atomic bomb factories.

It wasn't even the government that initially discovered this embarassment. Journalist Peter Shinkle began a series of articles May 6, 1991, in the BATON ROUGE [LOUISIANA] TIMES about DOE shipping radioactively-contaminated chemical wastes to a Baton Rouge incinerator operated by Rollins Environmental Services--a facility not licensed to accept radioactive wastes. Shinkle's articles led first to a DOE investigation and later, on February 20, 1992, to a public hearing held by California Congressman George Miller and the House Committee on Interior and Insular Affairs.

Leo P. Duffy, a DOE assistant secretary, testified February 20 that between 1984 and 1991 some 113,000 cubic yards of radioactive wastes (about 200 boxcar-loads weighing 7000 tons) were shipped illegally to eleven chemical waste disposal facilities (incinerators and dumps): Aptus in Coffeeville, Kansas (1.6 million lb.); Chem Waste in Emelle, Alabama (4.2 million pounds); Chem Waste in Chicago (1.1 million lb.); Chem Waste in Sulpher, Louisiana (19,400 lb.); CECOS in Cincinnati, OH (133,000 lb.); ENSCO in El Dorado, Arkansas (3.6 million pounds); GSX (now Laidlaw) in Reidsville, North Carolina (18,766 lb.); LWD in Calvert City, Kentucky (86,440 lb.); Rollins in Baton Rouge, Louisiana (2.4 million lb.); Rollins in Deer Park, Texas (896,511 lb.); and SD Myers in Talmadge, Ohio (18,143 lb.). Duffy testified that 25 DOE sites had shipped illegal radioactive wastes and another 11 highly-suspect DOE sites remain to be checked. DOE hasn't had time to check the records from these additional sites because they have only known about the problem for nine months, he said. Duffy said, in all, perhaps 150 incinerators, landfills, fuel blending operations, recyclers and other waste facilities had accepted wastes from DOE but, so far, DOE has only confirmed that illegal RADIOACTIVE wastes went to 11 or 12 of them. DOE is continuing to investigate itself and its contractors, and Duffy promised to tell all as soon as all is known

At the hearing February 20, various waste companies sent top officials to testify. George VanderVelde, vice president of science and technology for Chemical Waste Management (Chem Waste) said his company has an extensive in-depth state-of-the-art program for analyzing incoming wastes for radioactivity and, he testified, "We have no indication that we received any undetected radioactive substances from DOE facilities."

The credibility of VanderVelde's testimony was undercut somewhat by subsequent testimony from Illinois Attorney General Roland W. Burris, who presented an internal memo from a Chem Waste employee dated February 6, 1992--two weeks before the hearing--saying that Chem Waste's Chicago incinerator was at that time holding 97 drums of illegal radioactive waste they had received a year earlier from DOE. Testimony indicated that Chem Waste had been unable to burn these particular illegal radioactive wastes because its incinerator had been shut down by an explosion in early 1991.

Martin Marietta Energy Systems--the company that operates the Oak Ridge National Laboratory (Oak Ridge, Tennessee), the Paducah Gaseous Diffusion Plant (Paducah, Kentucky), and the Portsmouth Gaseous Diffusion Plant (Portsmouth, Ohio)--sent its president, Clyde Hopkins, to testify that his employees had been illegally shipping radioactive wastes to waste disposers like Rollins and Chem Waste for years. He said his employees used white-out illegally to delete information from shipping manifests indicating that the wastes were radioactive because they believed "national security considerations" required them to. He said enemies of the United States might glean valuable information about U.S. atomic weapons by studying the wastes his staff had been shipping illegally to Chem Waste and Rollins and the others. He testified that his staff had been shipping uranium-238, uranium-235 and technetium-99 mixed in with chemical wastes. Additional information attached to his testimony indicated Martin Marietta had reason to believe iodine-129, neptunium-237, and thorium-232 were also being shipped off-site to various incinerators and landfills. (It is worth noting that the federal air pollution standard for thorium-232 is now five times stricter than the standard for plutonium-239, so tiny amounts of such wastes are dangerous.)

C. Randolph Warner, Jr., chairman of ENSCO, a major waste incinerator company in Arkansas, which burned nearly 4 million pounds of DOE's illegal radioactive wastes during the 1980s, testified there was no problem. All the wastes his company burned were safe, he said, including the illegal radioactive ones.

The total radioactivity shipped illegally by DOE was 1/10th of a Curie, the DOE testified, and they trotted out a risk assessment to show that, on average, probably no one would have been harmed by dumping such small amounts of radioactivity into the environment. This is the old averaging trick, commonly used in risk assessments. Unfortunately, in the real world individuals don't get exposed in an "average" way. Many may not be exposed at all; a few may be exposed a great deal; the average exposure remains low but those few people are in danger. It's like the fellow said: if all the air were removed from this room for 10 minutes, the average amount of air during the year would hardly change at all, but we would all be dead.

The problem of radioactive waste gets worse every time anyone looks. April 9, Ohio's Senator John Glenn (Senate Committee on Governmental Affairs) held a public hearing to announce that a draft study by U.S. Environmental Protection Agency (EPA) has identified a minimum of 45,361 potentially radioactively contaminated sites across the U.S. Every state has some. Colorado tops the list with 7,060 sites; Vermont has only 36. This includes every place EPA could figure out where radioactivity has ever been present. Not all these sites are contaminated in a serious way but most are and will require cleanup. Just the DOE's 108 facilities--many of which are large, complex and badly contaminated--are presently estimated to cost $160 billion to clean up over the next 30 years. This estimate is almost certainly low.

In addition to the 45,361 potentially contaminated sites--some 15 or 20 thousand of which may actually require cleanup--there are another 1.5 million oil and gas wells where, it was discovered last year, radioactive radium-226 and radium-228 have been brought to the surface along with oil and gas. The insides of oil extraction pipes are coated with a "scale" containing radium up to 100,000 times higher than natural background levels. In addition, much radioactivity from oil and gas wells has been dumped into shallow pits. In some cases, oil companies have donated old oil pipes to schools and municipalities, which have made jungle gyms, swing sets and parking lot barriers out of them. If old oil pipes are recycled, along with their radioactivity, the radioactivity will be incorporated into new metal products.

At Senator Glenn's hearing April 9, Dan Reicher from Natural Resources Defense Council (NRDC) noted that the government has never taken official notice of the radioactivity measurable in ash produced by burning coal. There are some 52,400 coal-burning power plants and industrial units, all of which are producing an ash elevated in radioactivity a few times higher than natural background levels.

EPA Deputy Assistant Administrator Michael Shapiro testified April 9 that 1.1 billion tons of NORM (naturally occurring radioactive material) wastes are produced each year by mineral processing, coal power production, oil and gas exploration and production, geothermal energy production, phosphorus and fertilizer production, and water treatment. Such wastes are entire ly unregulated.

Then there is wood ash, which, it was announced last year, is radioactive as well. During the 1950s and 1960s, the United States tested atomic bombs above-ground in Nevada. The resulting radioactive fallout swept eastward, blowin' on the wind. The radioactive strontium and cesium settled out onto the ground and, as time passed, migrated into the soil. A-bomb enthusiasts assumed, optimistically, that it had gone away.

In 1989, Stewart A. Farber, who manages environmental monitoring for the Yankee Atomic Electric Company in Bolton, Massachusetts, wondered if radioactive strontium and cesium from bomb fallout had been taken up by tree roots.[1] On a whim he took some ash from his home fireplace and tested it in his lab. It was about 100 times more radioactive than any other environmental sample he had ever checked. Now two years later, Farber has checked 47 samples gathered by 16 scientists in 14 states and he says wood ash "is a major source of radioactivity released into the environment." Only wood ash from California (upwind of the Nevada test site) seems free of radioactive fallout.

Industrial wood burning produces an estimated 900,000 tons of ash each year; residential and utility wood burning generate another 543,000 tons. Many companies recycle their wood ash into fertilizer.

Farber says current regulations require wastes from a nuclear power plant to be disposed of as radioactive wastes if they contain one percent as much radioactivity as is found in wood ash from New England.

Radioactivity is widely acknowledged to cause inheritable genetic changes, immune system damage, reproductive damage, developmental disorders, and cancer. It is also widely acknowledged that the only truly safe dose of radiation is zero.

From the viewpoint of radioactive contamination alone, it makes sense to begin phasing out petroleum, uranium, and coal. And for similar reasons, presented earlier (see RHWN #225, #263, #264), it would be smart to phase out chlorine, too.

Phase out or ban petroleum, uranium, chlorine and coal. That simple, far-reaching formula would keep 90% of contemporary environmental problems from getting worse.

--Peter Montague, Ph.D.

===============

[1] Janet Raloff, "Wood ash: The unregulated radwaste," SCIENCE NEWS August 10, 1991, pg. 95.

Descriptor terms: doe; radioactive wastes; ks; al; cecos; ensco; ar; gsx now laidlaw; nc; lwd; ky; tx; sd myers; oh; cwmi; radioactive wastes; radioactivity; martin marietta energy systems; oak ridge national laboratory; tn; paducah gaseous diffusion plant; portsmouth gaseous diffusion plant; landfills; uranium; iodine; epa; nrdc; norms; stewart a. faber; yankee atomic electric company; ma; wood ash;coal; radioactive waste; pollution;

#281: Hazardous Waste Incinerators: A Technology Out Of Control?

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #281
---April 15, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ========== RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com. =======================Original Source========================

Throughout the late 1970s and early 1980s, EPA (U.S. Environmental Protection Agency) learned the hard way that landfills always leak and usually contaminate groundwater. So the agency kept making new restrictions on what chemicals could be buried in the ground. Because the agency did next to nothing to promote waste avoidance and pollution prevention, industry continued to produce more and more hazardous waste each year. Thus each year a larger and more diverse brew of toxins has been sent to the nation's 18 huge commercial hazardous waste incinerators.

There is now a decade's experience indicating that hazardous waste incinerators have never worked as designed, create massive pollution themselves, and periodically explode. Furthermore, as we saw last week, #280 EPA scientists have known since 1985 that hazardous waste incinerators cannot destroy wastes to the extent required by law.

This week we focus on the human management failures of incineration technology.

Chemical Waste Management is the nation's largest and wealthiest operator of hazardous waste incinerators. If anyone can afford to run an incinerator properly, Chem Waste can. Furthermore, the company says environmental compliance drives everything it does. Some of the parent firm's top executives donate time to sit on the boards of directors of prominent environmental organizations like Audubon and National Wildlife Federation. They have a vice-president in charge of environmental policy AND ethical standards. If anyone were capable of running an incinerator well, it would seem to be this company.

Yet during recent years Chem Waste's two incinerators have racked up a list of leaks, spills, releases, explosions, violations and coverups that would fill a hefty book.[1]

Standard operating procedure says:

--all wastes must be sampled and incompatible wastes must never be mixed, BUT CHEM WASTE HAS MIXED INCOMPATIBLE WASTES TOGETHER, CAUSING CHEMICAL REACTIONS THAT SENT PLUMES OF WASTES WAFTING OFF-SITE.
--The rate at which wastes can enter the furnace is carefully specified, YET CHEM WASTE ON SEVERAL OCCASIONS HAS BEEN CAUGHT FEEDING WASTES AT EXCESSIVE RATES, REDUCING THE EFFECTIVENESS OF WASTE DESTRUCTION.
--Temperatures in the furnace must be maintained at 1600 degrees or higher, YET CHEM WASTE SOMETIMES BURNS WASTES AT TEMPERATURES OF ONLY 1300 DEGREES.
--CO (carbon monoxide) must not exceed 500 ppm in the stack gas, YET CHEM WASTE HAS PERMITTED CO TO EXCEED THIS LIMIT.
--Manifests are supposed to say where all the wastes came from, YET CHEM WASTE HAS FAILED TO MAINTAIN PROPER MANIFESTS.
--Operating records are supposed to be kept, YET CHEM WASTE HAS FAILED TO KEEP THEM PROPERLY.
--Waste in leaking containers is supposed to be transferred to new containers, YET CHEM WASTE HAS FAILED TO DO THIS IN SOME CASES.
--All wastes are supposed to be sampled to avoid putting explosives into the furnace, YET BOTH CHEM WASTE INCINERATORS HAVE EXPLODED DURING THE PAST YEAR, OFFERING CLEAR EVIDENCE OF FAILURE TO IDENTIFY WASTES PROPERLY.
--Explosions are to be reported when they happen, YET CHEM WASTE HAS FAILED TO REPORT EXPLOSIONS AT ITS INCINERATORS.
--Waste feed is supposed to cut off automatically when hydrochloric acid (HCl) in the stack gas exceeds 100 ppm BUT CHEM WASTE HAD THEIR CUT-OFF SET FOR 500 PPM HCL.
--Chem Waste's incinerators are not licensed to burn dioxins, BUT ON DECEMBER 3, 1991, CHEM WASTE'S INCINERATOR AT SAUGET, ILLINOIS BURNED A 25-MILLIGRAM VIAL OF DIOXIN--ENOUGH DIOXIN TO PROVIDE A MAXIMUM ALLOWABLE LIFETIME DOSE FOR 232,000 PEOPLE.

The preceding list barely scratches the surface. How could these lapses, violations and pollution disasters occur? If the company can't control it's own technology, what about government? The person responsible for developing EPA's hazardous waste incinerator regulations back in 1978 was William Sanjour. In a recent letter to a grass-roots activist, Sanjour offered several reasons why the regulations, as finally written, don't work:[2]

"I've talked to many people who live near hazardous waste sites and I have reviewed many records, and this is the way it really works," Sanjour wrote. "Inspectors typically work from nine to five Monday through Friday. So if the incinerator has anything particularly nasty to burn, it will do so at night or on weekends. When the complaints come in to the inspector's office the next day he will call the incinerator operator and ask what's going on. He may also visit the plant but rarely finds anything. The enforcement officials tend to view the incinerator operator as their client and the public as a nuisance."

"Keep in mind that hazardous waste is a factory's garbage. If they typically ship out say a thousand gallons a month of waste solvents and they find themselves with say fifty gallons of waste PCB which they don't know what to do with. What is more natural than dumping it in with the waste solvent to be hauled away to the incinerator? No one would be the wiser," Sanjour wrote. 

He offered other reasons as well:

--The regulations require no monitoring of ambient air in the vicinity of the incinerator.
--It's easy for an operator to cheat because he or she produces and maintains the records.
--Government inspectors are typically poorly trained. They have low morale and high turnover. EPA statistics show that 41% of inspectors have conducted fewer than 10 inspections. "There is no reward to inspectors for finding serious violations and, indeed, zealous inspectors are typically given a hard time by their supervisors," Sanjour wrote.

* * *

Recent events at the Jacksonville, Ark., incinerator (not a Chem Waste facility) appear to follow a script that might have been written by William Sanjour.[3]

The Jacksonville site manager, Robert Apa, issued respirator masks to all employees and sent an inter-office memo April 1 ordering everyone to keep their masks handy because of dangerous "puffs" of pollution being emitted from the furnace, which has begun burning 16 million pounds of dioxin-contaminated chemical warfare wastes left over from Vietnam. Seals in the fire box are leaking, and periodically, for reasons that are not understood, pressure builds up inside the furnace, forcing "puffs" of contaminants to escape. The puffs last from 5 to 45 seconds and, of course, represent emissions that entirely bypass the pollution control system. The Jacksonville incinerator was constructed in the middle of a residential neighborhood, over the objection of local citizens, as a demonstration of the manly prowess of the government-industry partnership that developed during the governorship of Bill Clinton.

When news of the puffs got out, Mark McCorkle, an Arkansas state official assigned to regulate the Jacksonville incinerator, first tried to pressure the ARKANSAS DEMOCRAT-GAZETTE (the state's largest paper) not to print anything about it. McCorkle then conceded that the pollution "puffs" posed a potential hazard to workers, but denied that the public could be affected when the puffs drifted off-site to the homes that lie a long stone's-throw from the furnace. "If you were to take this memo out of context, it would appear to be a horror story," McCorkle said.

Site manager Apa stressed the difficulty of preventing the puffs. He said, "We have taken measures via procedural changes and a new interlock, to minimize the duration [of the puffs.] However, as soon as one problem is identified, another seems to appear. This last week, the slag dams caused release of unburned material onto the TDU pad."

Jacksonville citizens continue to work desperately to shut down the incinerator. A new group, Jacksonville Mothers and Children Defense Fund (JAMAC), will soon file a lawsuit seeking shutdown. They are asking groups everywhere to sign on to their suit. For details, contact Sharon Golgan at JAMAC, 1105 Wilds, Jacksonville, AR 72076; phone (501) 982-4366. Or contact attorney Gregory Ferguson in Little Rock: telephone (501) 372-0771.

After a decade of experimentation and experience, the record now indicates that hazardous waste incinerators cannot be operated safely even when the operator desires to do so. If the operators have any inclination to cut corners, regulatory officials seem unwilling or unable to bring them to justice.

--Peter Montague, Ph.D.

===============


[1] Jeff Bailey, "Concerns Mount Over Operating Methods Of Plants That Incinerate Toxic waste," WALL STREET JOURNAL March [20,] 1992, pg. B1, B5. And: Julia Flynn, "The Ugly Mess at Waste Management," BUSINESS WEEK April 13, 1992, pgs. 76-77. Court records related to Chem Waste's Sauget, IL, and Chicago incinerators provide details of the many problems we have listed.

[2] Correspondence from William Sanjour to Terri Swearingen dated March 27, 1992. Eight pages; available from us for $2.00.

[3] Sandy Davis, "Incinerator Safety Stiffened," ARKANSAS DEMOCRAT-GAZETTE April 9, 1992, pgs. 1, 10A.

Descriptor terms: epa; landfilling; groundwater; incineration; hazardous waste; chemical waste management; cwmi; explosions; compliance; carbon monoxide; co; sauget; il; dioxin; hcl; hydrochloric acid; william sanjour; enforcement; pcbs; jacksonville; ar; cbw; vietnam; bill clinton; jacksonville mothers and children defense fund; jamac; chicago;

#283: Waste Wars: The Army Opens a New Front

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #283
---April 29, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ========== RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com. =======================Original Source========================

Here's the emerging picture of hazardous waste disposal in the U.S.:

Citizens have blocked construction of all new hazardous waste dumps. There are no new dumps on the drawing boards. EPA [U.S. Environmental Protection Agency] is aggressively promoting hazardous waste incinerators because the alternative--waste avoidance and pollution prevention--would inconvenience the generators of hazardous waste. Rather than inconvenience anyone with power and connections, EPA is promoting incinerators. It's really that simple.

Industry likes incinerators because liability for toxic waste disappears when the waste enters the incinerator. From the Superfund dump-cleanup program where they're spending billions defending themselves against lawsuits, industry knows the liability problem is serious. Incinerators solve this problem because after chemicals pass through an incinerator, there are no labels left on the barrels to identify responsible parties. Most of the waste goes up the smoke stack and can't be traced. The incinerator company--not the original waste generator--bears responsibility for the toxic ash, but in the scheme of things incinerator companies are relatively small and can declare bankruptcy when their ash dumps begin to leak, a few decades from now. EPA will then put the ash dumps on the Superfund list, and the taxpayer will bear all the costs. It's a practical system and it should work.

The only hitch is that citizens are blocking the siting of new incinerators. So EPA is cooperating with the U.S. Army and the Department of Energy (DOE) to solve this problem. The Department of Energy has announced plans to site a huge, privately-owned incinerator on the Hanford Reservation in Washington state. DOE has produced plutonium for A-bombs at Hanford for 40 years. DOE will deflect public outrage about siting the privately-owned incinerator, and Chem Waste will run it, despite Chem Waste's embarrassing record of failure running incinerators (see RHWN #280 and #281). For its part, the Army has announced plans to site eight huge chemical-waste incinerators at Aberdeen, Maryland; Richmond, Kentucky; Anniston, Alabama; Pine Bluff, Arkansas; Pueblo, Colo.; Newport, Indiana; Tooele, Utah; and Umatilla, Oregon. The Army's stated goal is to burn up old chemical warfare weapons that now aren't needed. At a public hearing at Aberdeen three weeks ago, the Army said with a straight face it will spend $500 million building the incinerator, use it for 14 months to destroy mustard gas and then dismantle it, never burning any other defense wastes or civilian wastes. Local people don't believe it, and they fear military incinerators would be as dangerous as civilian incinerators.

But let's be fair. Maybe the private incinerator companies have bungled the job merely because they are careless and cut corners to increase profits. The army would have no such motives and could perhaps be relied upon to do a better job. What do we know about Army experience running incinerators?

The military has already built and operated a modern, state-of-the-art incinerator specifically designed to destroy left-over chemical warfare weapons. To avoid a hassle with local citizens, they built the incinerator on an island in the South Pacific--Johnston Atoll. Environmentalists and local native people opposed the facility but that did not deter the Army. During the period July 16, 1990 through February 27, 1991, the Army fed 7490 M55 rockets containing 75,000 pounds of the nerve agent GB (also known as Sarin), into the Johnston Atoll Chemical Disposal System (JACADS). GB is among the most powerful nerve poisons ever developed.

The operation of the JACADS incinerator was evaluated by MITRE Corporation (McLean, Virginia) under contract to the Army. The MITRE report has been scrutinized by chemist Pat Costner, research director for Greenpeace. Her paper, "Chemical Weapons Demilitarization and Disposal: The Army's Experience at Johnston Atoll Chemical Disposal System," contains valuable data and insights into what we can expect from the Army's path-breaking chemical-weapons incineration program.[1]

Here are facts Costner gleaned from the book-length MITRE report:

** During the period of operation, the JACADS incinerator functioned for 500 hours but during the same period it experienced 929 hours of down-time because of malfunctions. The "mean (average) time between failures" throughout the period was 5.6 hours.
** During the 500-hour operating period when agent GB was being burned, the network of monitors for detecting GB releases triggered 776 major process alarms, an average of 22 per day. Major process alarms are "those that are so important that agent or spent decon[tamination] processing is stopped," according to the MITRE report.

A high level of carbon monoxide (CO) in smoke-stack gases is an indication of poor burning. Of the 776 major process alarms that occurred, "the majority" were for high carbon monoxide in the stack gas--a dead give away that the incinerator was experiencing "upsets."

During upset conditions, an incinerator emits large quantities of pollutants into the environment. The EPA Science Advisory Board says, "Even relatively short-term operation of incinerators in upset conditions can greatly increase the total incinerator-emitted loadings [pollution emissions] to the environment."

According to the MITRE report, the JACADS incinerator suffered 90 burner lockouts and 40 fuel flow shutdowns during the GB-burning campaign, further evidence of upsets. As Costner said in her report, "In other words, the [incinerator] operated in a continuous upset condition during the GB campaign."

On 32 occasions the JACADS incinerator released GB nerve agent into corridors frequented by workers. Furthermore, during 500 hours of incineration, the JACADS workforce accumulated 1944 hours of lost-time accidents. In other words, every hour of operation was accompanied by 3.9 hours of injury-related lost-time among the workers. Costner documents other serious problems with the Army's JACADS incinerator as well.

This is not good news. It means the Army's 8 proposed state-side incinerators will do no better--perhaps considerably worse--than civilian hazardous waste incinerators, which are poor indeed.

Inside their furnaces, incinerators destroy some chemicals, but in the process they create many new toxic by-products that did not exist before, all of which they emit into the environment partly via the smoke stack and partly via the ash, which is buried temporarily in a landfill until it leaks out. Among the most toxic of those chemicals are dioxins and furans. On January 27, 1992, EPA staff presented their latest findings about dioxins and furans to EPA chief William Reilly. RHWN has obtained a set of 24 acetate transparencies prepared by EPA staff for chief Reilly. They contain important new information about dioxin:

EPA's transparency 17 says:

RECENT SCIENTIFIC RESULTS AND CONCLUSIONS:

* DIOXIN DOES CAUSE CANCER IN HUMANS. 

* CANCER MAY NOT BE THE MOST SENSITIVE TOXIC RESPONSE RESULTING FROM DIOXIN EXPOSURE. IMMUNOTOXICITY AND REPRODUCTIVE EFFECTS APPEAR TO OCCUR AT BODY BURDENS THAT ARE APPROXIMATELY 100 TIMES LOWER THAN THOSE ASSOCIATED WITH CANCER. 

* RECENT DATA INDICATE THAT THERE MAY NOT BE A THRESHOLD FOR CERTAIN RESPONSES TO DIOXIN. HOWEVER, THE IMPLICATIONS FOR SPECIFIC RISK ASSESSMENTS, SUCH AS FOR CANCER, ARE NOT YET CLEAR. 

* RECENT EVIDENCE HAS STRENGTHENED THE CONCLUSION THAT THE SENSITIVITY OF HUMANS IS SIMILAR TO THAT OF EXPERIMENTAL ANIMALS (CANCER, IMMUNOTOXICITY, AH RECEPTOR BINDING, ETC.).

EPA's transparency 18 says:

NEW SCIENCE AND CONCLUSIONS......CONTINUED.

* CURRENT EXPOSURE LEVELS TO DIOXIN AND RELATED COMPOUNDS APPEAR TO PLACE PEOPLE AT OR NEAR THE BODY BURDEN WHEN SENSITIVE RESPONSES MAY OCCUR, ESPECIALLY FOR SUBPOPULATIONS AT HIGH-END EXPOSURE, E.G., NURSING INFANTS, RECREATIONAL AND SUBSISTENCE ANGLERS. 

* CONTINUING RESEARCH INTO THE RISK FROM DIOXIN EXPOSURE SHOULD RESULT IN A CONTINUING PROCESS OF REASSESSMENT AS NEW DATA BECOME AVAILABLE AND ARE INCORPORATED INTO A NEW, MORE FLEXIBLE MODEL. 

* ORD [EPA's Office of Research and Development] SCIENTISTS HAVE REACHED THE TENTATIVE CONCLUSION THAT DIOXIN EXPOSURE MAY HAVE BEEN RESPONSIBLE FOR THE DECLINE OF LAKE TROUT IN LAKE ONTARIO AS A RESULT OF THE REPRODUCTIVE TOXICITY OF DIOXIN.

Let's review briefly what EPA has said here:

One. Dioxin causes cancer in humans, but cancer is not the most sensitive indicator of damage from dioxin; damage to the immune system, and reproductive damage, are the most sensitive indicators.

Two. Animals and humans are about equally sensitive to damage from dioxin.

Three. The amount of dioxin presently in our food ("current exposure levels," EPA calls it) puts humans at or near the body-burden of dioxin at which "sensitive responses" [immune system damage, and damage to the reproductive system] may occur. Those at greatest risk are infants who drink their mother's breast milk, or people who eat more-than-average amounts of fish because fish accumulate these poisons in their tissues.

Four. In fact, it appears that because fish accumulate these poisons in the fat tissues of their bodies, and because fish eggs have a high fat content and therefore a high dioxin content, Lake Trout in the Great Lakes are not able to thrive. Evidently humans are not the only species endangered by dioxin.

The logical conclusion from EPA's data is that Americans cannot afford to increase the amount of dioxins and furans in their bodies--they are already at or near the levels where immune system damage and reproductive system damage occurs, especially babies. Thus all plans to build new incinerators in the U.S. stand in direct conflict with public health priorities. New incinerators (and uses of chlorine) should be banned, old ones phased out.

--Peter Montague, Ph.D.

===============

[1] Pat Costner, "Chemical Weapons Demilitarization and Disposal: The Army's Experience at Johnston Atoll Chemical Disposal System." (Washington, DC: Greenpeace, April 11, 1992). Available for $5.00 from Greenpeace, 1436 U St., NW, Washington, DC 20009. Telephone (202) 462-1177 and ask for Sanjay. There's a growing network of activists fighting all 9 of the Army's proposed incinerators; contact: Craig Williams, Kentucky Environmental Foundation, P.O. Box 467, Berea, KY [40403;] phone (606) 986-7840.

Descriptor terms: epa; doe; army; mitre; pat costner; nerve gas; johnston atoll; dioxin; cwmi; cbw; incineration; jacads;

#280: All Hazardous Waste Incinerators Fail to Meet EPA Regulations, EPA says

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #280
---April 7, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com ========================Original Source========================

Hazardous waste incinerators, and the web of regulations intended to make them operate safely, have come under withering criticism from government scientists, private researchers, and the WALL STREET JOURNAL during the last 60 days. Officials of EPA (U.S. Environmental Protection Agency) and private research scientists now admit that hazardous waste incinerators emit hundreds of times more dioxins and other toxic air pollutants than is allowed by EPA regulations, and the JOURNAL revealed a record of malfunctions, including explosions and major releases of toxins, that incinerator operators have tried to cover up and that regulatory officials seem powerless to understand, much less curtail.

Scientists employed by U.S. EPA (Environmental Protection Agency) admitted last month that modern hazardous waste incinerators simply cannot comply with existing federal regulations because they cannot destroy all chemicals with 99.99% destruction/removal efficiency (DRE), which is the efficiency required by federal law. Federal law further requires that certain wastes of "special concern" such as dioxins, furans, and PCBs must be destroyed with 99.9999% DRE. EPA scientists said last month that they have known since at least 1985 that hazardous waste incinerators could not meet any of these regulatory requirements.

The story broke when Pat Costner, a chemist and research director for Greenpeace, published an independent analysis of dioxin emissions from the Jacksonville, Arkansas incinerator.[1] The Jacksonville incinerator has begun burning 16.5 million pounds of herbicides (2,4,5-T and 2,4-D) left over from the Vietnam war. These wastes are known to be contaminated with total dioxins and furans at concentrations ranging from to 3 to 40 parts per million (ppm).

Costner's analysis revealed that the Jacksonville incinerator was only achieving 99.96% destruction of the dioxins entering the incinerator, thus emitting 400 times more dioxin into the community than the law allows. An official with the Arkansas Department of Pollution Control and Ecology (DPC&E) acknowledged in telephone interviews that Costner's calculations are correct. He also said the department had no intention of shutting down the incinerator despite its continuing emissions of dioxin directly into a residential community. He said the department did not know what the total dioxin emissions into the population of Jacksonville would be, but, he said, no matter what the total may be, it is safe.

The Jacksonville incinerator is a key demonstration project, established with the cooperation of EPA Administrator William Reilly and Arkansas Governor Bill Clinton to show that dioxin-containing wastes can be incinerated in a residential neighborhood over the objections of the community.[2] In a city-wide referendum in March, 1986, the people of Jacksonville voted two-to-one (1383 to 656) to stop the project but government officials simply ignored the vote and have overridden all objections ever since. Costner's analysis clearly showed that residents of Jacksonville are being exposed to levels of dioxin contamination that exceed federal health and safety standards by a wide margin. This is the first systematic dioxin experiment on humans using a residential population. Previous dioxin exposures of humans have occurred during industrial accidents and in the industrial manufacture of chemical-biological warfare agents. Dioxin is now known to cause cancer in humans and to disrupt normal growth and development of fetuses and infants at low levels of exposure.[3]

About 100 waste sites in the U.S. contain substantial quantities of dioxin,[4] and the U.S. has stockpiles containing billions of pounds of chemical-biological warfare (CBW) agents the government has said it wants to incinerate. If the Jacksonville dioxin experiment can be maintained despite ethical and public health objections, government agencies will be able to claim they have a green light to incinerate just about anything just about anywhere.

However the Jacksonville experiment has brought to light information that could derail the entire U.S. incineration program. In preparing her analysis of dioxin exposure of the Jacksonville populace, Costner uncovered a government study showing that tests in 1984-85 by private researchers, under contract to EPA, revealed that hazardous waste incinerators cannot be expected to achieve 99.9999 percent destruction of wastes that occur in concentrations lower than 10,000 parts per million, and cannot be expected to achieve 99.99 percent destruction of wastes that occur in concentrations lower than 1000 ppm. EPA published the 1985 data in 1989.[5]

When this information came to light, a news reporter from the ARKANSAS DEMOCRAT-GAZETTE, Sandy Davis, interviewed Bob Hall, chief of the EPA's Combustion Research Branch in Research Triangle, North Carolina, and he confirmed what the EPA report had shown. "The fact is that you run into problems with your DRE [destruction/removal efficiency] when a low concentration of wastes is fed into the incinerator," Hall said. "Our data clearly shows that," he said. Davis asked Hall why EPA hasn't changed its regulations since it knows existing incinerators cannot comply with the regulations. Hall said, "I don't know why that hasn't been changed. It's a regulatory issue. I'm in research."[6] Costner uncovered a second EPA report,[7] published in 1984 but never widely circulated, showing that, among eight major hazardous waste incinerators studied, none could achieve 99.99% DRE. Sandy Davis interviewed the author of that report, Drew Trenholm of the Midwest Research Institute in Research Triangle, North Carolina, who said incinerators simply cannot achieve the DRE required by federal law. "The trend is very strong in the data that this is the case," Trenholm told Davis.

At public hearings over the past decade, dozens of EPA officials have stated for the record that incinerators can achieve the legally-required DREs, in what appears to be a coverup of public health information of astonishing proportions.

Many of the most dangerous toxins such as dioxins, furans, and PCBs occur in wastes at low concentrations. If low-concentration chemicals cannot be destroyed effectively, this means all sludge incinerators, all contaminated-soil burners, and all wood-treatment-waste incinerators will fail to meet federal regulations and will emit illegal quantities of potent toxins into surrounding air.

Ongoing failure to achieve the required destruction efficiencies is not all that plagues incinerators. WALL STREET JOURNAL reporter Jeff Bailey pointed out March 20 that federal, state and local regulatory officials pay close attention to hazardous waste incinerators but they can't be everywhere at the same time and they often learn about accidents, explosions and violations from tips phoned to them anonymously by insiders.[8] For example, Chem Waste, the nation's largest hazardous waste hauler, is not considered a fly-by-night operator. According to Joan Bernstein, vice-president for environmental policy and ethical standards at Chem Waste, "Environmental compliance is what drives this company."

If this is true, then Chem Waste's ongoing record of accidents, explosions, leaks, releases and coverups involving their incinerators must mean that even the wealthiest companies that have written down their best intentions on a piece of paper still cannot operate hazardous waste incinerators in a fashion that any reasonable person would call safe.

[To be continued.] #281

--Peter Montague, Ph.D.

===============

[1] Pat Costner, THE INCINERATION OF DIOXIN IN JACKSONVILLE, ARKANSAS: A REVIEW OF TRIAL BURNS AND RELATED AIR MONITORING AT VERTAC SITE CONTRACTORS INCINERATOR, JACKSONVILLE, AR (Washington, DC: Greenpeace Toxics Campaign, January 29, 1992).

[2] Stephanie Arbanel and others, "Toxic Nightmare on Main Street," FAMILY CIRCLE August 14, 1990, pgs. 77-80, 120-128.

[3] Karen F. Schmidt, "Puzzling Over a Poison; On closer inspection, the ubiquitous pollutant dioxin appears more dangerous than ever," U.S. NEWS & WORLD REPORT April 6, [1992,] pgs. 60-61.

[4] Peter A. Johnson and others, DIOXIN TREATMENT TECHNOLOGIES: BACKGROUND PAPER [OTA-BP-O-93] (Washington, DC: U.S. Government Printing Office, 1991). 80 pages. $4.00 from U.S. Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-7954 or phone your order to (202) 783-[3238.]3238.

[5] John C. Kramlich and others, EXPERIMENTAL INVESTIGATION OF CRITICAL FUNDAMENTAL ISSUES IN HAZARDOUS WASTE INCINERATION (Springfield, VA: National Technical Information Service [NTIS], September, 1989.) This is EPA document No. EPA/600/2-89/048 available from NTIS for $26.00; phone (800) [553-6847] and request NTIS document No. PB90-108507.

[6] Sandy Davis, "Incinerator can't do job, engineer says," ARKANSAS DEMOCRAT-GAZETTE March 14, 1992, pgs. 1A, 15A.

[7] A. Trenholm and others, PERFORMANCE EVALUATION OF FULL-SCALE HAZARDOUS WASTE INCINERATORS. VOL. I. EXECUTIVE SUMMARY. [EPA/600/2-84/181A]. (Washington, DC: U.S. Environmental Protection Agency, 1984). Available from NTIS as document No. PB 85-129500. $17.00. Phone 800/553-6847.

[8] Jeff Bailey, "Concerns Mount Over Operating Methods Of Plants That Incinerate Toxic Waste," WALL STREET JOURNAL March 20, 1992, pgs. B1, B5.

Descriptor terms: hazardous waste; incineration; regulation; wall street journal; epa; dioxin; air pollution; accidents; federal; furans; pcbs; pat costner; greenpeace; ar; pesticides; health; birth defects; cbw; sludge incineration; cwmi; jacksonville;

#279: New Study Links Breast Cancer to DDT, PCBS and Other Chlorinated Chemicals (sexual behavior)

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #279
---April 1, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com ========================Original Source========================

A new study[1] of women with breast cancer reveals that their breast tissues contain elevated levels of DDT, DDE and PCBs, compared to breast tissues of women with non-cancerous breast disease. DDT is a well-known, persistent pesticide banned in 1972; DDE is a byproduct of the natural breakdown of DDT in the environment; PCBs are persistent industrial toxins banned in 1976.

"This is a very important study," said Dr. Richard Clapp of the JSI Center for Environmental Health Studies in Boston, and former director of the Massachusetts Cancer Registry. "We should all pay close attention to this one," he said.

Although the number of women involved is small, the new study adds to a growing body of evidence indicating that many chlorinated hydrocarbons mimic female hormones and disrupt the human reproductive system and immune system. PCBs, DDT, and DDE are all chlorinated hydrocarbons, and all have been found to mimic female hormones in recent studies of wildlife and of laboratory animals.[2]

The new breast-cancer study will appear in the March/April, 1992, ARCHIVES OF ENVIRONMENTAL HEALTH.[1] A team of researchers from University of Michigan, Mt. Sinai School of Medicine (New York), and Hartford Hospital in Hartford, Connecticut, led by Dr. Frank Falck, Jr., conducted the study of 40 women who had been examined at Hartford Hospital between May and September, 1987 for palpable breast mass or mammographic abnormality. Tissue biopsies had been done for diagnostic purposes and this study looked at chemical contaminants in the tissue samples. Half the women had been diagnosed with breast cancer and half had been diagnosed with non-cancerous breast disease (mostly benign cysts).

The two groups of women were comparable in age (average of 63 among the cancer cases, and 59 among the non-cancer control group). There were appreciably more smokers among the non-cancer controls (15 out of 20) than among the cancer group (6 out of 20). Average height and weight were nearly identical for the two groups.

The average (mean) concentration of PCBs, DDT, and DDE were 50% to 60% higher in the women with cancer. Concentrations in the fatty tissues of the cancer cases were: DDT 216 ppb [parts per billion], DDE 2200 ppb, PCBs 1965 ppb.

The causes of breast cancer are not well understood. Known risk factors include age at which menstruation begins (later is safer), and onset of menopause (earlier is safer). Both these factors suggest that female hormones may be involved in this particular cancer. Nevertheless, when all the know risk factors for breast cancer are taken into account, they explain less than half the 179,500 cases that occur each year among U.S. women. Therefore, researchers are looking for evidence that perhaps chemicals in the environment, mimicking hormones, may cause breast cancer in humans, as well as causing other disturbances of the reproductive and immune systems.

Two weeks ago, scientists concerned about chlorinated hydrocarbons in the environment held a symposium in Washington, DC, to share information on the hormone-like qualities of DDT, DDE, PCBs, dioxins, furans and others.[2] Scientists at the symposium, which was initiated by Dr. Theo Colborn of the World Wildlife Fund, examined the growing body of knowledge about environmental chemicals that mimic female hormones.

The symposium emphasized disruptive effects of these chemicals on fetuses. SCIENCE TIMES (a section of each Tuesday's NEW YORK TIMES) reported some of the findings from the symposium this way:

The Effects Of The Chlorinated Organic Chemicals Are Most Significant In Fetuses. They Include Partial Retention Of Sex Glands Of The Opposite Gender, Profound Changes In Sexual Behavior, And Reduced Fertility. In Some Studies, Laboratory Rodents Exposed As Fetuses To Even Small Doses Of Pcbs And Dioxins Were Born As 'Feminized' Males Or 'Masculinized' Females.... 

Studies With Rats, Mice And Sea Gulls Have Shown That Fetuses Exposed To Various Environmental Hormone Mimics Fail To Develop Normal Sex Organs, Or Even Develop Partly Formed Double Sets Of Sex Organs. 

Dr. [Michael] Fry [A Wildlife Research Physiologist At University Of California, Davis] Reported That Unusual Sexual Behaviors Have Been Observed Among Gulls In The Wild In Contaminated Regions Like The Seas Off Southern California And The Islands In The Great Lakes. Male Gulls Ignored Breeding Colonies, And Pairs Of Female Gulls Tried To Nest Together, As If One Were Male. There Appeared To Be A Correlation Between The Amounts Of Pollutant Chemicals In Their Bodies And The Degree Of Unusual Sexual Behavior.... 

A Second Study [By Dr. Dick Peterson Of The University Of Wisconsin School Of Pharmacy], In Which Mother Rats Received From 0.064 Microgram To 1 Microgram Per Kilogram Of Body Weight Of Tcdd [Dioxin], Showed There Were Striking Alterations In Sex-Linked Behavior Among The Male Offspring At Maturation. The Males Showed A Marked Reluctance To Mount A Sexually Receptive Female Compared With A Control Group Of Males That Had Not Been Exposed To Tcdd In Utero [Before Birth]. They Also Produced Half The Usual Amount Of Sperm And Took Twice As Long To Ejaculate. 

"We Found That Perinatal [Near The Time Of Birth] Tcdd Exposure Alters Sexually Dimorphic Responses That Affect The Brain," Dr. Peterson Said. "It Decreases The Expression Of Masculine Sexual Behavior. And It Increases The Expression Of Feminine Sexual Behavior." He Said The Effects On Brain Function That Apparently Occurred 

When The Rats Were Fetuses And Newborns  

Were Probably Permanent And Irreversible.... 

Hormone-Like Contaminants In The Environment May Produce Several Other Sorts Of Damage, Researchers Suggested, Including Suppression Of The Immune System, Thyroid Dysfunction, Decreased Fertility, And Birth Defects.

It would be unthinkable to experiment on humans to see if they suffer from similar aberrations after exposure to dioxin or other hormone-mimicking chemicals while in the womb or shortly after birth. Nevertheless, the symposium was told, the now-banned drug diethylstilbestrol (DES) may have served as a human experiment of sorts. The drug, once prescribed to millions of women, mimics natural sex hormones just as chlorinated organics are now thought to do.

Both sons and daughters of DES-treated women have suffered from malformed reproductive systems, infertility, and rare cancers. The sons and daughters were exposed to DES in the womb, but the consequences did not become clear until they matured.

Dr. John McLachlen, director of the Laboratory of Reproductive and Developmental Toxicology at the National Institute of Environmental Health Sciences said, at this point researchers are sure of only three points: that certain chemicals act like estrogens [female hormones] in the environment; that in experimental animals you can perturb the reproductive system with these chemicals; and that you see some of the same effects in humans exposed to DES.

One other thing seems certain: American women have been exposed to chlorinated hydrocarbons for decades and they carry these chemicals in their breast tissues and milk.

A study by EPA (U.S. Environmental Protection Agency) of Americans in 1975-76 revealed that 99% of American women had detectable levels of DDT and DDE in their breast milk. The average concentration of DDT in the lipid (fat) portions of the milk had 553 ppb (parts per billion); the average DDE concentration was 3521 ppb. Other chlorinated hydrocarbons, such as PCBs, are present in breast milk as well.

[3] Chlorinated hydrocarbons are more soluble in lipids than in water, so they tend to concentrate in body fat and milk fat. In women, lactation is the principle route by which such chemicals are excreted from the body.

Many scientists emphasize that the benefits of breast-feeding still outweigh the adverse consequences. Because breast-fed babies receive immunity to disease with their mother's milk, breast-fed babies have fewer infections than those who are bottle-fed, studies show. The important lesson from this information is not to discourage breast feeding, but to phase out or ban chlorinated hydrocarbons.

--Peter Montague, Ph.D.

===============

[1] Frank Falck, Jr., Andrew Ricci, Mary S. Wolff, James Godbold, and Peter Dreckers, "Pesticides and Polychlorinated Biphenyl Residues in Human Breast Lipids and Their Relation to Breast Cancer." ARCHIVES OF ENVIRONMENTAL HEALTH Vol. 47 No. 2 (March/April, 1992), pgs. 143-146.

[2] Jon R. Luoma, "New Effects of Pollutants: Hormone Mayhem," NEW YORK TIMES March 24, 1992, pgs. C1, C9.

[3] U.S. Environmental Protection Agency, NATIONAL STUDY TO DETERMINE LEVELS OF CHLORINATED HYDROCARBON INSECTICIDES IN HUMAN MILK, 1975-76. Available from National Technical Information Service [NTIS]; telephone (703) 487-4650 and request publication no. PB284393; price: $35.00.

Thanks to Carol Van Strum of Alder-Hill Associates, Tidewater, OR for this. Regarding PCBs, see: Allan Astrup Jensen, "Background Levels in Humans," in Renate Kimbrough and Allan Astrup Jensen, editors, HALOGENATED BIPHENYLS, TERPHENYLS, NAPHTHALENES, DIBENZODIOXINS, AND RELATED PRODUCTS (NY: Elsevier Science Publishers, 1989), pgs. 345-[380.]

Thanks to Tom Webster, CBNS, Queens College, Flushing, NY, for this.

Descriptor terms: breast cancer; pesticides; dde; pcbs; health; reproductive hazards; mt sinai school of medicine; hartford hospital in hartford; birth defects; sexual behavior; thyroid dysfunctions; infertility; des; cancer; dioxin; estrogen; epa;