**********************************************************
  
  The following document, titled
  
        "DIOXIN REASSESSED: A GENERAL OVERVIEW" 
  
  was prepared for COPA by Environmental Compliance
  Organization (ECO), COPA's technical assistance grant (TAG)
  contractor.  Paper copies are available upon request, or you
  may download this file from the "main" file library on this
  bulletin board.
  
  ***********************************************************
  
    
                      DIOXIN REASSESSED:
                      A GENERAL OVERVIEW
  
                           OUTLINE
  
  
  I.   Introduction
  
  
  II.  What is Dioxin?
  
  
  III. Health Risks Posed by Dioxin and Dioxin-like Chemicals
  
  
  IV.  Views of Some Scientists in the Public Interest
         Community
  
  
  V.   Media Reports on the Dioxin Issue
  
  
  VI.  Recommendations for Community Awareness
  
  
  This document is printed on recycled paper utilizing non-toxic 
  vegetable based inks.
  
  *********************************************************
  
    
  
  I.   Introduction
  
  
      This overview is designed to provide current information
  from health experts, scientific literature, and government
  reports regarding the likely human health impacts from
  exposure to dioxin and dioxin-like chemicals. Dioxin
  and/or dioxin-like chemicals are likely to exist in areas
  contaminated by pesticides and pesticide by-products.
  Moreover, additional dioxin may be created by the use of
  cleanup technologies employing burning or excessive heat
  to destroy or free chemical contaminants from soils and
  other contaminated materials.
  
        The information below is presented in summary form to
  give the reader a general overview of the impacts of dioxin. 
  
  
    II.  What is Dioxin?
  
      In 1989 the U.S. Agency for Toxic Substances and Disease
  Registry(ATSDR) described dioxin as follows:
  
         The chlorinated dibenzo-p-dioxins are a class of
         compounds that are loosely referred to as dioxins.
         There are 73 possible dioxins. The one with four
         chlorine atoms at positions 2, 3, 7, and 8 of the
         dibenzo-p-dioxin chemical structure is called
         2,3,7,8-tetrachlorinated dibenzo-p-dioxin
         (2,3,7,8-TCDD). It is a colorless solid with no
         known odor ... It can be inadvertently produced in
         very small amounts as an impurity during the
         manufacture of certain herbicides and germicides
         and has been detected in products of incineration
         of municipal and industrial wastes.
  
       The ATSDR toxicological profile also described some of
  the potential sources of dioxin.
  
       The main environmental sources of 2,3,7,8- TCDD are:
  
       *    Use of herbicides containing 2,4,5-
            trichlorophenoxy acids (2,4,3-T)
  
       *    Production and use of 2,4,5- trichlorophenol in
            wood preservatives
  
       *    Production and use of hexachlorophene as a
            germicide
  
       *    Improper disposal of certain chlorinated chemical
            wastes 
  
       Although 2,4,5-T, 2,4,S-trichlorophenol, and
  hexachlorophene are no longer produced commercially ...
  disposal sites of past production wastes are still sources 
  of present exposure. 2,3,7,8-TCDD has been found in at least
  28 of 1,177 hazardous waste sites on the [[Superfund]
  National Priorities List (NPL).1 (1) Of the members of the
  dioxin family referred to by ATSDR, 2,3,7,8- TCDD is viewed
  as the most potent.
  
      In September 1994, in its most recent reassessment
  effort, the U.S. Environmental Protection Agency (EPA)
  described dioxin in a similar manner.  Chlorinated 
  dibenzo-p-dioxins and related compounds (commonly known simply 
  as dioxins) are contaminants present in a variety of
  environmental media. This class of compounds has caused
  great concern in the general public as well as intense
  interest in the scientific community.
  
       Much of the public concern revolves around the
  characterization of these compounds as among the most potent
  man-made" toxicants ever studied. Indeed, these compounds
  are extremely potent in producing a variety of effects in
  experimental animals based on traditional toxicology studies
  at levels hundreds or thousands of times lower than most
  chemicals of environmental interest. (2) 
    
       Beyond the 73 member dioxin family referred to by ATSDR
  there are dioxin-like chemicals. These chemicals have
  structures similar to dioxin and may pose comparable health
  concerns. There are literally thousands of chemicals that
  have a dioxin-like chemical structure. In general, the
  differences may be that they are chlorinated, brominated, or
  a combination of chlorinated and brominated. EPA described
  the family of dioxin-like chemicals as follows.
  
      There are 73 individual compounds comprising the CDDs,
  depending on the positioning of the chlorine(s), and 133
  different CDFs. These are called individual congeners.
  Likewise, there are 73 different positional congeners of
  BDDs and 133 different congeners of BDFs ... There are 209
  PCB congeners ... Mixed chlorinated and brominated congeners
  also exist increasing the number of compounds considered
  dioxin-like. (3) Thus, particularly where dioxin is present,
  the presence of dioxin-like chemicals must also be
  considered.
                                                      
  
    III. Health Risks Posed by Dioxin and Dioxin-Like Chemicals
  
      A.  EPA's 1994 Reassessment
  
      EPA has been involved in The assessment of dioxin and
  dioxin-like chemicals for more than five years. The effort
  to assess the health effects of dioxin has been coupled with
  an analysis of how best to estimate the exposures (e.g.
  sources of exposure, routes of ingestion into the body,
  expected health effects, etc.) to dioxin-like chemicals.(4)
  EPA described the history of the dioxin assessment work as
  follows:
  
      In 1983 and 1988; the Agency prepared assessments of the
  human health risks from environmental exposures to dioxin.
  
      Also, in 1988, a draft exposure document was prepared
  that presented procedures for conducting site-specific
  exposure assessments to dioxin-like compounds. These
  assessments were reviewed by the Agency's Science Advisory
  Board (SAB). At the time of the 1988 assessments, there was
  general agreement within the scientific community that there
  could be a substantial improvement over the consensus as to
  a more biologically defensible methodology. The Agency was
  asked to explore the development of such a method. The
  Agency's [[September 19941 reassessment activities are in
  response to this request. (5)
  
       EPA's description of the dioxin reassessment effort is
  rather bland. In the view of many in the environmental
  community, dioxin health risk issues were "reassessed" at
  the insistence of industry. Fortunately, a number of
  impartial scientists have been involved in the EPA's
  reassessment effort, making the analysis at least somewhat
  beneficial. Over the last few months EPA took comments on
  the 1994 reassessment documents and hopes to finalize them
  within about one year.
  
       What follows are important excerpts from EPA's current
  draft reassessment volumes. This summary is designed to give
  the reader a significant sampling of EPA's analysis
  regarding dioxin.
  
       1.  Effects on the Immune System
  
      Extensive evidence has accumulated over the past 20
  years to demonstrate that the immune system is a target for
  toxicity of... TCDD ... and structurally related halogenated
  aromatic hydrocarbons (HAHs), including the polychlorinated
  dibenzofurans(PCDFs), polychlorinated biphenyls (PCBs), and
  polybrominated biphenyls (PBBs). This evidence was derived
  from numerous studies in various animal species, primarily 
  rodents, but also guinea pigs, rabbits, monkeys, marmosets,
  and cattle. Epidemiological studies also provide evidence
  for the immunotoxicity of HAHs in humans. EPA 1994 at 4-1.
  
       2.  Reproductive Effects
  
       The potential for dioxins and related compounds to
  cause reproductive and developmental toxicity has been
  recognized for many years. Recent laboratory studies have
  broadened our [EPA's] knowledge in this area and suggest
  that altered development may be among the most sensitive
  TCDD endpoints.(6) EPA 1994 at 5-1.
  
  
      3.  Cancer Effects
  
       There have been several long-term studies designed to
  determine if TCDD is a carcinogen in experimental animals.
  All of these studies have been positive and demonstrate that
  TCDD is a multi-site carcinogen, is a carcinogen in both
  sexes and in several species including the Syrian hamster,
  is a carcinogen in sites remote from the site of treatment,
  and increases cancer incidence at doses well below the MTD.
  EPA 1994 at 638.
  
  
       The mechanistic basis for inter-individual variation is
  unclear, and this lack of knowledge complicates approaches
  to estimate human risks from experimental animal data.
  However, several studies indicate that, for the most part,
  humans appear to respond like experimental animals for
  biochemical and carcinogenic effects.  EPA 1994 at 6-39 - 6-40.
  
  ...although there are uncertainties associated with the
  epidemiological evidence that could have influenced risk
  estimates, the overall weight of the evidence from the
  epidemiologic studies suggests that the generally increased
  risk of cancer is more than likely due to exposure to TCDD.
  The consistency of this finding in the four major cohort
  studies is corroborated by animal studies that show TCDD to
  be a multi-site, multisex, and multispecies carcinogen. EPA
  1994 at 7J7.
  
      4.   Other Effects
  
       TCDD alters a number of other pathways involved in the
  regulation of cell differentiation and proliferation. The
  specific relationships of these effects to multistage
  carcinogenesis are not known, but the broad array of effects
  on hormone systems, growth factor pathways, cytokines, and
  signal transduction components is consistent with the notion
  that TCDD is a powerful growth dysregulator. EPA 1994 at 6-38.
  
       Human exposure to ... TCDD ... has been associated with
  non-cancer effects in most systems. The majority of effects
  have been reported among occupationally exposed groups, such
  as chemical production workers, pesticide users, and
  individuals who handled or were exposed to materials treated
  with ... TCDD-contaminated pesticides, and among residents
  of communities contaminated with tainted waste oil
  (Missouri, USA) -and industrial effluent (Seveso, Italy).
  EPA 1994 at 7-87.
  
  
   5.  Overall Conclusions
  
      EPA's September 1994 reassessment draft makes the
  following overall conclusions regarding the impact of dioxin
  and related chemicals on human health.
  
            a.  Exposure sources and background levels
  
      The principal identified sources of environmental
  release of CDDs and CDFs may be grouped into four major
  types: combustion and incineration sources; chemical
  manufacturing processing sources; industrial/ municipal
  processes; and reservoir sources EPA 1994 at 9-73 - 9-76.
  
       Exposure levels to ... TCDD in industrialized nations
  are estimated to be about 0.3-0.6 pg [[picograms] TCDD/ kg
  body weight/ day. EPA 1994 at 9-77.
  
       Estimates of exposure to dioxin-like CDDs and CDFs
  based on dietary intake are in the range of 1-3 pg TEQ/kg
  body weight/ day.
  
  
       Estimates based on the contribution of dioxin-like PCBs
  to toxicity equivalents raise the total to 3-6 pg TEQ/kg
  body weight/day. This range is used throughout this
  characterization [[EPA reassessment] as an estimate-of
  average background exposure to dioxin-like CDbs, CDFs, and
  PCBs. This average background exposure leads to body burdens
  in the human population that average 40-60 pg TEQ/ g lipid
  (40-60 ppt [[parts per trillion]) when all dioxins, furans,
  and PCBs are included. High-end estimates of body burden
  of individuals in the general population (approximately the
  top 10% of the general population) may be greater than three
  times higher. EPA 1994 at 9-77 - 9-78.
  
  
       With regard to average intake, humans are currently
  exposed to background levels on dioxin-like compounds on the
  order of 3-6 pg-TEQ/kg body weight/day, including dioxin
  like PCBs. This is more than 500 fold higher than EPA's 1983
  risk-specific dose associated with a plausible upper bound,
  ... and several hundred fold higher than revised risk
  specific dose estimates ... Plausible upper-bound risk
  estimates for general population exposures to dioxin and
  related compounds, therefore, may be as high as ... one in
  ten thousand to one in a thousand ... EPA 1994 at 9-86.
  
       b.  Toxicity and non-cancer effects
  
       TCDD is the most potent form of a broad family of
  xenobiotics that bind to an intracellular protein known as
  the Ah receptor. Other members of this family include
  halogenated hydrocarbon such as the PCBs, naphthalenes, and
  dibenzofurans, as well as nonhalogenated species such as 
  3-methyleholanthrene and B-naphthaflavone. The biological
  properties of dioxins have been investigated extensively in
  over 3,000 publications and abstracts since the
  identification of TCDD as a chloracnegen ... [[in 1957].
  EPA 1994 at 8-1.
  
       From the complex picture that evolves from the ...
  data, it is amply evident that TCDD elicits a plethora of
  toxic responses, both after short term and long term
  exposure. EPA 1994 at 3-34
  
  ...based on the results of two or more studies, recent
  evidence suggests that chloracne, elevated GGT (7) levels,
  an increased risk of diabetes, and altered reproductive
  hormone levels (luteinizing hormone, follicle-stimulating
  hormone, and testosterone) appear to be long term
  consequences of exposure to ... TCDD ... EPA 1994 at 7-238.
  
  
       Based on all of the data reviewed in this reassessment
  and scientific inference, a picture emerges of TCDD and
  related compounds as potent toxicants in animals with the
  potential to produce a spectrum of effects. Some of these
  effects may be occurring in humans at very low levels and
  some may be resulting in adverse impacts on human health.
  [[emphasis in original] EPA 1994 at 9-87.
  
  
      c.   Cancer effects
  
       With regard to carcinogenicity, a weight of the
  evidence evaluation suggests that dioxin and related
  compounds (CDDs, CDFs, and dioxin-like PCBs) are likely to
  present a cancer hazard to humans. [emphasis in original]
  EPA 1994 at 9-83.
  
  
    V.     VIEWS OF SOME SCIENTISTS IN THE PUBLIC INTEREST
         COMMUNITY
  
      Several scientists in the fields of public health,
  toxicology, chemistry, and risk assessment have provided
  somewhat stronger or more direct comments on the impacts and
  concerns related to human exposure to dioxin-like chemicals.
  For example, public health expert Dr. Richard Clapp has
  testified that there is no safe level of exposure to
  dioxin.(8) Dr. Clapp added that in his opinion there was
  ample evidence to establish that dioxin causes cancer in
  humans.(9)
                        
       Dr. Peter Kahn (10) has noted that dioxin causes
  immunosuppressive and reproductive effects.(11) Recently,
  Dr. Kahn wrote a paper with other scientists examining the
  potential long term impacts of TCDD on children born to
  mothers who lived in a dioxin-contaminated environment. The
  conclusion of the paper was stated as follows:
  
         The results appear to demonstrate that immune
         deficiencies caused by in utero and post-natal exposure
         to TCDD may persist for 10 years or more.(12) In a
         second and related study similar conclusions were
         reached regarding other long-term effects of dioxin
         exposure.  The TCDD exposed children exhibited
         neurophysiological dysfunction principally in the
         bilateral frontal lobe regions relative to unexposed
         children, with females exhibiting more dysfunction than
         males.(13)
  
       The work of Dr. Kahn and others is important to
  consider when evaluating current and future exposures to
  dioxin-like chemicals.
  
       Dr. Peter Montague has been a frequent analyst and
  chronicler of the impacts of dioxin and dioxin-like
  chemicals.(14) Dr. Montague has noted that there is a
  growing body of disturbing research indicating that dioxin-
  like chemicals (e.g. dioxins, furans, PCBs, pesticides) may
  be seriously impacting male reproductive systems. What
  follows are condensed reports taken from Rachel's
  Environment & Health Weekly.
  
      * Research during the past decade has shown that there
  are two basic ways that chemicals can affect male
  reproduction [[footnotes omitted]. Chemicals can directly
  affect the testes, where sperm originates. The number of
  sperm can be diminished, or some sperm can be damaged, or
  sperm may eventually carry toxins directly to the egg.
  
       Alternatively, toxins can attack The male nervous
  system, or endocrine system, affecting the flow of hormones
  that act as messengers regulating the complex chemical
  processes that must all work well for conception to occur.
  
      No matter what the mechanism of damage may be, there is
  a growing body of evidence showing that male exposures to
  toxins can produce defective children. (15) [emphases added]
  
            A recent study in the British Medical Journal
  concludes that men in western countries today have sperm
  counts less than half as high as their grandfathers had at
  the same age [[footnote omitted]. In addition, the
  occurrence of cancer in the testicles has increased
  3-fold to 4-fold during the past 40 years; and various birth
  defects of the male reproductive system have increased 2-fold 
  to 4-fold during the same period, including undescended
  testicles (a condition called cryptorchidism) and a birth
  defect called hypospadias in which the male urinary canal is
  open for a variable distance on the underside of the penis.
  
  
            * An article in ...The Lancet... asks whether
  these phenomena can all be traced to the same cause, namely
  exposure of males very early in life to female sex hormones
  (estrogens) or to environmental chemicals that act like
  estrogens [[footnote omitted].
       
         These findings and hypotheses add to the growing
  body- of medical knowledge indicating that many chemicals --
  especially chlorinated hydrocarbons -- mimic hormones and
  interfere with the endocrine systems of fish, birds,
  wildlife and humans. Earlier studies have linked chlorinated
  hydrocarbons to female breast cancer ... and it is worth
  pointing out that breast cancer in women is associated with
  an increased likelihood of testicular cancer in their sons
  (footnote omitted). Thus breast cancer, testicular
  cancer, and defects of the male reproductive system,
  including diminished sperm count, all seem linked. (16)
  (emphasis added]
  
       Sharing the views and concerns of Dr. Montague is Dr.
  Barry Commoner. Dr. Commoner is considered by many to be one
  of the key scientific figures responsible for stimulating
  the environmental movement in the United States. Dr.
  Commoner is well versed in the disciplines of risk
  assessment, environmental science and public health.
  Regarding dioxin, Dr. Commoner extensively studied the
  environmental and human health impacts of the chemical for
  many years. He has carefully studied the dioxin
  contamination impacts of the industrial accident in Seveso,
  Italy. The Seveso incident is one of the most well known
  dioxin contamination incidents in the world.
  
      As an expert witness in the case challenging the
  operation of the Waste Technologies Industries (WTI)
  hazardous waste incinerator, Dr. Commoner testified that
  dioxin causes immune system defects and acts as a kind of
  environmental hormone. (17) He went on to testify that
  exposure to any level of dioxin will have an effect, noting 
  further that if there is little or no benefit from
  an action that releases dioxin then public health principles
  dictate that the action should not be taken. (18)
  
      Most recently, as the keynote speaker at the Second
  Citizens' Dioxin Conference, Dr. Commoner provided a further
  warning to citizens and government regulators about the
  impacts of dioxin.
  
      The general spread of dioxin and dioxin-like chemicals
  in the U.S. environment has already exposed the entire
  population to levels of these extremely toxic substances
  that are expected to cause a number of serious health
  effects. These include an average risk of cancer of 100 or
  more per million in the entire U.S. population 100 times
  greater than the risk standard that has triggered EPA
  remedial action, for example at Times Beach in Missouri
  Superfund site].(19)
  
      In evaluating the results of EPA's current dioxin
  reassessment effort The Environmental Defense Fund (EDF) and
  Physicians for Social Responsibility(PSR), in part, reached
  the following conclusions:
  
        The only way to reduce contaminants of food is for the
  federal government to take comprehensive action to protect
  the food supply. This is the best way to safeguard the
  public at large, particularly young children and developing
  fetuses, who are the most sensitive to dioxin's effects.
  
      The proper response to EPA's report [[September 1994
  dioxin reassessment] is to recognize that dioxin exposure is
  now a threat to public health. Many Americans arc ingesting
  levels of dioxin that could adversely affect their health. 
  That's why we must reduce the sources of exposure to dioxin
  and to all of the related chemicals that have similar
  toxicities. For ourselves and for future generations, we
  must take preventative action by strictly controlling
  emissions and keeping these toxic chemicals out of the
  environment. (20)
  
       In reviewing an early draft of EPA's 1994 Dioxin
  Reassessment, Dr. Montague and his colleagues reached
  similar conclusions.
  
      ...average levels of dioxin already present in the
  bodies of average Americans -- or levels not more than 10
  times as high as average levels seem to be capable of
  damaging the immune system, reducing sex hormones in the
  blood stream of men, interfering with glucose metabolism (a
  condition suggestive of diabetes), and causing other
  negative changes in health and well being.
  
      ...the average amount of dioxin in Americans is 9
  nanograms per kilogram (ng/kg) of body weight; a nanogram is
  a billionth of a gram and there are 28 grams in an ounce ...
  sex hormones are diminished in men with 13 ng/kg; altered
  glucose tolerance has been observed in humans with 14 ng/kg;
  decreased growth is observable in humans having 47 ng/kg;
  endometriosis is produced in monkeys having 27 ng/kg.
  
         EPA's best estimate is that existing levels of dioxin
  in the U.S. population may be sufficient to cause cancer in
  somewhere between one-in-every-thousand people and one-in-
  every-ten-thousand people each year
  
       ... Another way to estimate the size of the cancer
  hazard is to note that .... dioxin in food and air may be
  causing somewhere between 75,000 and 150,000 cancers each
  year. (21)
  
       How much dioxin is "safe"?  EPA's answers: For cancer
  hazards?  Three hundred to 600 times less than we all now
  intake every day ... For non-cancer hazards? Ten to 100 
  times less than we all now take in every day .(22)
  
    V.  MEDIA REPORTS ON THE DIOXIN ISSUE
  
       The media, particularly non-mainstream press and
  technical publications, have not missed the dioxin issue and
  its effects on a variety of industries.  however, aside form
  the occasional local news coverage abut a particular site or
  facility, the television and radio networks seem to have
  missed the story almost entirely.
  
       The general public knows little of the scientific and
  political controversies surrounding dioxin.  a small sample
  of some print media stories gives an anecdotal account of
  dioxin coverage.
  
       In 1991, chemistry & Industry magazine reported on the
  interests of certain industries in the "reassessment" of
  dioxin.
  
       ...scientists are challenging the very basis of EPA's
  approach to risk assessment for dioxin.  The Chloralkli
  industry, which has come under pressure as environmentalists
  target paper bleaching as a source of dioxin, has taken an
  active interest in the course of the scientific debate.
  
       Concern about the environmental blacklisting of its
  products has been serious enough to prompt a "public
  outreach program" coordinated by the Chlorine Institute.
  (23)
  
      The political controversy surrounding the assessment of
  dioxin was well described in an article in the Multinational
  Monitor.
  
       In the face of mounting public concern over toxic      
       chemical pollution, several industries and their allies
       in government  have launched a full scale campaign to  
       reverse the long-held belief that dioxin is the most   
       toxic chemical known to science. If the government, the
       courts and the public accept what many scientists      
       believe the evidence [[about the effects of dioxin] has
       already demonstrated ... the chlorine, waste      
       incineration and pulp and paper industries stand to         
       lose billions of dollars through lawsuits and lost     
       contracts. (24)
  
       Other stories have also published the bad news about
  dioxin-like chemicals (like PCBs) and some pesticides and
  their effects on reproductive systems.  These
  articles stress the concern about impacts on fertility and
  breast cancer. (25)
  
  
  
    VI.  RECOMMENDATIONS FOR COMMUNITY AWARENESS
  
      As noted in previous comments to EPA, thorough testing
  of dioxin and dioxin-like chemicals in water and soil in and
  around the Bloomington sites is imperative. PCBs which has
  been subjected to incomplete burning, as is the case
  here, frequently results in residues of dioxin and/or
  dioxin-like chemicals. The public health implications and
  environmental impacts from exposures to contaminated air,
  water, and soil from the Bloomington sites prior to
  remediation is possibly significant. This problem is
  exacerbated by the current dangerous levels of dioxins
  already contained in our bodies.
  
      Moreover, the community must be seriously concerned
  about the additional exposures that will occur during
  remediation. As noted in this review, ingestion of certain
  pesticides, dioxin, and/or dioxin-like chemicals in
  unimaginably small quantities can cause 1) birth defects by
  damaging male or female reproductive systems, 2) immune
  system dysfunction, 3) endocrine system damage, and 4)
  cancer. Pregnant women, women of childbearing age,
  children, persons with illnesses, and elderly persons are
  particularly susceptible to the impacts of these ultra-toxic
  chemicals. Given the history of activities at the site,
  medical monitoring of longtime residents of the area is
  needed.
  
       In addition, the community must insist on no further
  exposure to dioxin or related chemicals coming from the
  Bloomington sites either before, or during remediation. (26)
  
       For these crucial health and safety reasons, all
  interested and affected persons must monitor EPA's remedial
  process at these sites and voice their concerns accordingly.
  
  
  
  
  
    REFERENCES
  
  (1)   ATSDR.  1989.  Toxicological  Profile  for  2,3,7 8-
        Tetrachlorodibenzo-P-Dioxin. Report # ATSDR/TP-88/23.
         p. 1.
  
  (2)    Health Assessment Document for 2,3,7,8-Tetrachlorodibenzo-
         p-Dioxin (TCDD) and Related Compounds, EPA/600/BP-92/001?, 
         U.S. EPA, August 1994 at 9-1.  Hereafter this document 
         will be referred to as "EPA 1994."
  
  (3)    EPA 1994 at 9-6 to 9-7.
  
  (4)    The current dioxin health assessment and estimating
         dioxin exposures documents can be referenced through
         EPA as  follows.  Health assessment documents: Volume I
         (chapters I - 6) (EPA/600/BP-92/OOla); Volume II
         (chapters 7 and 8) (EPA/600/BP-92/OO1b); Volume III
         (chapter 9) (EPA/600/BP-92/OO1c). Estimating exposures
         documents: Volume I (EPA/600/6-88/OO5ca); Volume II
         (EPA/600/6-88/OO5Cb); Volume III (EPA/600/6-88/OO5cc).
  
  (5)    Gerber: "Reassessment of 2,3,7, 8-Tetrachlorodibenzo-p-
         dioxin (2,3,7,8-TCDD, dioxin)", August 30, 1994, at 5.
         Note: this document was handed out when EPA released
         the latest draft Documents on September 13, 1994.
  
  (6)  Two tables that describe the effects of dioxin on
         animals and humans are Volume I, page 3-35, and Volume
         II, page 7-239. 
  
  
  (7)    Gamma glutamyl transpeptidase.
  
  
  (8)    Greenpeace V. Waste Technologies Indus., No. 4:
         93CVOOS3 (N.D. Ohio), Testimony of Dr. Richard Clapp,
         February 8, 1993, at 26 - 27.
  
  (9)    Greenpeace v. Waste Technologies Indus., No. 4:
         93CV00S3 (N.D. Ohio), Testimony of Dr. Richard Clapp,
         February 8, 1993, at 36.
  
  
  (10)   Dr. Kahn was qualified before the Maryland Office of
         Administrative Hearings as an expert in biochemistry,
         toxicology of dioxins and related compounds in humans,
         animals, and the environment.  In the Matter of the
         Montgomery County Resource Recovery Facility, No. 9l-
         MDE-AMA-0l3-2301, March 28, 1992, at 141.
  
  (11)   In the Matter of the Montgomery County Resource 
         Recovery Facility, No. 91-MDE-AMA-0l3-2301, March 28,
         1992, at 146.
  
  
  (12)   See, Kahn, Rodgers, Suffin, Moconnachie: "In Utero
         Postnatal Exposure to 2,3,7,8-TODD in Times Beach,
         Missouri: I. Immunological Effects: Lymphocyte
         Phenotype Frequencies" at 1.
  
  (13)   Cantor, Holder, Cantor, Kahn, Rodgers, Smoger, Swain,
         Berger, and Suffin: " In Utero and Postnatal Exposure
         to 2,3,7,8-TCDD in Times Beach, Missouri: 2. Impact on
         Neurophysiological Functioning" at 1.
  
  
  (14)   Dr. Montague is editor of the publication Rachel's
         Environment & Health Weekly (formerly Rachel's
         Hazardous Waste News. The work of Dr. Montague and his
         capable colleagues is published by the Environmental
         Research Foundation.
  
  
  (15)   Environmental Research Foundation, Rachel's Hazardous
         Waste News # 321: "Male Reproductive System is Harmed
         by Toxic Exposures, Causing Birth Defects, Sterility,"
         January 20, 1993
  
  (16)   Environmental Research Foundation, Rachel's Hazardous
         Waste News # 343: "Are Environmental Chemicals Causing
         Men to Lose Their Fundamental Masculinity?," June 24,-l993.  
         See also  Environmental Research Foundation,
         Rachel's Hazardous Waste News # 372: "PCBs Diminish
         Penis Size," January 13, 1994.
  
  (17)   Greenpeace v. Waste Technologies Indus., No. 4:
         93CV0083 (N.D. Ohio), Testimony of Dr. Barry Commoner,
         February 16, 1993, at 669.
  
  (18)   Greenpeace v. Waste Technologies Indus., No. 4:
         93CV0083 (N.D. Ohio), Testimony of Dr. Barry Commoner,
         February 16, 1993, at 672.
  
  (19) Reported by the Environmental Research Foundation,
         Rachel's Environment & Health Weekly # 405: "Turning
         Point for the Chemical Industry," September 1, 1994.
  
  
  (20) "Putting" the Lid on Dioxins- Protecting Public Health
         and the Environment,"  A joint report by Physicians for
         Social Responsibility and the Environmental Defense
         Fund, at 2.
  
  (21) Environmental Research Foundation, Rachel's Hazardous
         Waste News # 390: "Dioxin Reassessed -- Part 1, " May
         19, 1994.
  
  (22) Environmental Research Foundation, Rachel's Hazardous
         Waste News # 390: "Dioxin Reassessed -- Part 2, " May
         26, 1994.
  (23) Chemistry & Industry: "Scientists challenge EPA
         standards", February 18, 1991 at 112.
  
  (24) Multinational Monitor: "Defenders of Dioxin- The
         corporate campaign to Rehabilitate Dioxin", October
         1991, at 8.
  (25) See, Chemical & Engineering News: "Environmental
         Estrogens Linked to Reproductive Abnormalities,
         cancer", January 31, 1994, at 19 - 23; Newsweek: "The
         Estrogen complex", March 21,1994, at 76 - 77; The
         Nation: "A Toxic Link to Breast cancer", June 20, 1994,
         at 866 - 869.
  
  (26) Combustion and/or thermal processes (like thermal
         desorption or incineration) will create additional
         dioxins. EPA has noted that the formation of dioxin and
         dioxin-like chemicals can occur at temperatures in the
         range of 250 -  450 C (482 - 842 F). Thermal desorption
         units typically heat contaminated soil to temperatures
         ranging from 600 - 950 F.
  
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