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Terry Creek Technical Assistance Update
November 2007

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."


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