We received several PowerPoint presentations relating
to toxaphene in the marsh and marsh fauna, and a memorandum on toxaphene
calculations from the “Simon and Manning” paper on toxaphene monitoring
target levels. The PowerPoint presentations - “Terry Creek Overview” dated
August 2007, “Toxaphene Residues in Sediment and Fish Tissues from
Terry/Dupree Creeks” dated August 2007 (Maruya), and “Analyses of Toxaphene
and Chlorinated Camphenes in Extracts of Environmental Media,” undated —
were very general and did not add much to the discussion of finding a
universal monitoring standard for toxaphene.
Taken in the aggregate the discussions only reaffirm that toxaphene is one
and the same with polychlorinated camphene, which we already knew.
Regardless if it is “weathered” or “technical” toxaphene the data clearly
shows that the presence of any of the congeners that make up polychlorinated
camphene is scientific evidence of toxaphene contamination, and preceding
toxaphene with an adjective such as “weathered” is just semantics.
The September 5, 2007 memorandum “Derivation of PRGs for Weathered Toxaphene
and ∑3PC” is supposed to be an explanation of how the Simon and Manning
proposal for toxaphene is interpreted by the EPA. In their paper Simon and
Manning argue that just a few of the hundreds of toxaphene congeners are
indicative of toxaphene contamination, and all of the other hundreds of
congeners can be ignored if found. The memo from the EPA was to detail how
Region 4 can justify using the Simon and Manning model, given the
preponderance of evidence going back 30+ years for toxaphene present in the
environment as dozens or hundreds of congeners. However, the memo merely
quotes or paraphrases the original paper without augmenting with new
information, and there is no attempt at advancing the discussion for the
Simon and Manning model. The memo is basically a circular argument from one
bureaucrat at the EPA to another bureaucrat at the EPA without any attempt
to provide a scientific rationale for their support for the paper. There may
not be any underlying scientific basis supporting Region 4’s insistence on
this weak model, it may simply be institutional bias.
"This project has been funded wholly or
partly by the U.S. Environmental Protection Agency under Assistance
Agreement Number 1984482-98-0 to The Glynn Environmental Coalition, Inc. The
contents of this document do not necessarily reflect the views and policies
of the U.S. Environmental Protection agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation for use."